Privacy Policy

Last Modified: July 18, 2022

Direct Virtual Care, LLC d/b/a Ohla Medical (“Ohla,” “we,” “us,” or “our”) respects your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit our websites, applications, and other online products and services that link to this policy (collectively, the “Services”) or when you otherwise interact with us, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

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 the Services, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

1. Information We Collect About You and How We Collect It

We collect several types of Personal Information from and about users of our Services as described below. “Personal Information” means any information that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other information reasonably linkable to you with or without other identifying information in our possession.

There are three general categories of Personal Information we collect: (A) Information you provide to us; (B) Information we automatically collect from your use of the Services; (C) Information we collect from third parties.

1. Information You Provide to Us  

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

• Account Information: When registering or creating an account for our Services, as appropriate, you may be asked to enter your name, email address, phone number, or other details to create your account. 
• Transaction Information. When you conduct a transaction with us or a third party through the Services, you may provide information to complete the transaction, such as payment information (for example, credit card information or financial account information for another type of payment), demographic information (for example, age, date of birth, gender, or zip code).
• Information that you provide by filling in forms through our Services. This includes information provided at the time of registering to use the Services or in order to request our Services. We may also ask you for information when you request technical or customer support, communicate with us, or apply for a job with us.

2. Information Collected Automatically  

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

• Log Information. We collect 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. We may collect information about your location, such as your IP address or zip code.
• Cookie Information. We and our service providers may use various technologies to collect information on how you use the Services, or how your devices access the Services, such as cookies, web beacons, mobile device identifiers, and other technologies. We do not support the Do Not Track browser option.

3. Information We Collect from Other Sources

We may obtain additional information about you from third parties and use it as described in this policy. This may include combining the 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. 

2. Note on Protected Health Information

Please note that this policy does not apply to your health or medical information that is protected by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), also called “Protected Health Information” or “PHI.” In accessing and using the Services, we may collect and request that you provide information as described above (Information We Collect About You and How We Collect It) that we do not consider to be PHI. 

However, in using certain parts of the Services, you may provide information that is considered PHI and protected by HIPAA. Ohla is not a “covered entity” under HIPAA, but in some cases may be a “business associate” of the healthcare providers you interact with in the Services. To the extent Ohla is a "business associate," and solely in its role as a business associate, Ohla will use and disclosure your PHI in compliance with HIPAA and any applicable state laws regulating medical information. Any information that does not constitute PHI under applicable laws may be used or disclosed in any manner permitted under this Privacy Policy. PHI does not include information that has been de-identified in accordance with applicable laws.

The healthcare providers that you will interact with and who will perform the health care services and/or medical care within the Ohla Services are not employees or agents of Ohla. By accessing or using any part of the Services, you are acknowledging and authorizing your PHI to be used and disclosed by and on behalf of OpenLoop Healthcare Partners, PC, and its affiliates (together, the “Provider Group”). The Provider Group has its own privacy policy (the “Notice of Privacy Practices”) that describes how it uses and discloses PHI, and by accessing or using the Services, you are acknowledging receipt of the Notice of Privacy Practices from the Provider Group.

3. Cookies and Other Tracking Technologies

The technologies we use for the automatic data collection listed above may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience in our Services. This type of information is collected to make the Services more useful to you and to tailor the experience with us to meet your special interests and needs.
• Web Beacons. Pages of our Services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, 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). 

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 Services. 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 Services.

Some content or applications on the Services are served by third parties, including 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 Services. 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.

4. How We Use Your Information

We may use information about you to:

• Provide, maintain, operate, improve, enhance, administer, and troubleshoot our Services and your experience with them.
• Carry out our obligations and enforce our rights in providing the Services to you, including processing transactions such as billing and payment.
• Track and analyze trends and usage of the Services.
• Communicate with you, including customer support, notifications or reminders related to our Services, billing and other offers and information that we believe may be of interest to you.
• Detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of Ohla and others.
• Monitor, protect, and secure our systems.
• Comply with our licensing, legal, and regulatory obligations.
• Carry out any other purpose for which the information was collected.
• For any other purpose with your consent.

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.

We also may use aggregated or de-identified information, which cannot reasonably be used to identify you, for various purposes, including, for example, to improve our automation and improve care. Once aggregated or de-identified, the data does not personally identify you, is no longer personal information, and is not subject to this policy.

5. Sharing of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. 

We may share your personal information as described in this policy:

• To provide the Services to you, including to contractors, service providers, and other third parties who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. Examples of the functions that may be performed by those we share information with are treatment, pharmacy fulfillment, processing of payments, data storage, hosting of our website, marketing of our products and services, conducting audits, and performing web analytics.
• To our subsidiaries and affiliates.
• To a buyer or entity in the event of a merger, divestiture, restructuring, dissolution, or other sale or transfer of some or all of Ohla’s assets. This policy will continue to apply to your personal information in such case.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also sell or share aggregated or de-identified information, which cannot reasonably be used to identify you.

6. Choices About How We Use and Share Your Information

We aim to provide you with choices regarding the personal information you provide to us. Those choices include: 

• Cookies and Tracking Technologies. You can use the browser or device that you are using to access and view the Services to enable, disable or delete Cookies. Please note, you may experience some loss of functionality if you choose to disable certain Cookies.
• Promotional Offers from Ohla. You may opt out of receiving promotional communications from us by following the instructions in those communications. If you opt out, we may still send you non-promotional communications, such as those about your account, updates to this policy, or our ongoing business relations.
• Correction and Deletion. You can correct certain account information, such as email address or phone number associated with your account, in your account settings. You can delete your account at any time. Please keep in mind we are required to retain certain limited information for legal and regulatory purposes.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by messaging hello@ohlamedical.com. For this opt-out to function, you must have your browser set to accept all browser cookies. 

Our Services may contain links to other web sites. Other web sites may also reference or link to our Services. These other web sites are not controlled by Ohla. We encourage our users to be aware when they leave our Services to read the privacy policies of each and every web site that collects personally identifiable information. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other web sites or mobile applications. Visiting these other web sites is at your own risk.

Residents of California may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

7. Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To learn more about California residents' privacy rights, visit Additional Information For Residents of California. California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to hello@ohlamedical.com.

8. Privacy of Children

Our Services are not intended for children under the age of 18. No one under age 18 may provide any personal information to our Services. We do not knowingly collect personal information from children under 18.

9. Data Security

We have implemented reasonable measures to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services.

10. Changes to Our Privacy Policy

We may modify or update this policy periodically with or without prior notice by posting the updated policy on this page. You can always check the “Last Updated” date at the top of this document to see when the policy was last changed. If we make any material changes to this policy, we will notify you by e-mail or post a notice of the changes on our website prior to the changes becoming effective. We encourage you to check this policy from time to time. IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING OHLA AND SERVICES AFTER THE EFFECTIVE DATE OF SUCH CHANGES (WHICH IS THE “LAST UPDATED” DATE).

11. Contact Information

To ask questions or comment about this policy or to register a complaint or concern, please contact us at hello@ohlamedical.com.