Website and Services Privacy Policy (“Policy”)

Last modified: February 1, 2025

Introduction

Laguna Health, Inc. ("Company," "We," “Laguna,” or “Us”) respect your privacy and we 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 the website www.LagunaHealth.Com (our "Website") and the services available through our Company (collectively, the “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

On this Website.
Through the provision of products and Services.
In email, text, and other electronic messages between you and this Website.
Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
Through third parties.

It does not apply to information collected by:

Us offline or through any other means, including on any other website operated by Company or any third party; or
Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.

By visiting the Website or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Website or Services, and any dispute over privacy, is subject to this Policy and our Terms of Use including its applicable limitations on damages and the resolution of disputes. The Terms of Use are incorporated by reference into this Policy.

Please note: if you disagree with any term provided herein, please refrain from using our Services and this Website.

Your continued use of this Website or the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

II. Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at: privacy@lagunahealth.com

Residents of certain states under 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see “Your State Privacy Rights” for more information.

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

We may collect several types of information from and about users of our Website and the Services.

Information You Provide to Us.

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

Information that you provide by filling in forms on our Website.
We may ask you for information when you report a problem with our Website.
Records and copies of your correspondence (including email addresses), if you contact us.

Information We Collect Through Automatic Data Collection Technologies.

On our Website:

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

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

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

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.

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

Cookies (or browser cookies) and similar device and browsing information. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Our Use of Cookies and Other Tracking Mechanisms
We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Website or Services. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf).
- Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Website and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Website and Service. There are two types of cookies: session and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Website and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Website and Services.
- Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can change your browser options to block them in the future on each device and each browser. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Website who disable cookies will be able to browse certain areas of the Website, but some features may not function.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs, or pixel tags), in connection with our Website and Services to, among other things, track the activities of Website visitors Services users, help us manage content, and compile statistics about Website usage. We and our third-party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
Third Party Analytics. We use automated devices and applications, such as Google Analytics and to evaluate usage of our Website. We also may use other analytic means to evaluate our Website. We use these tools to help us improve our Website’s performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Other Technologies. In addition to cookies, we use log files, pixel tags and other tracking technologies to automatically collect information when users access or use our Services, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, searches, features used, Internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information.
Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

For information about managing your privacy and security settings for cookies and other items above, see Choices About How We Use and Disclose Your Information.

From Users of our Services:

Our Services require the use of your Name, email, and phone number for User credentialing and identification purposes.

From Consumers Recorded by our Services:

Communications and interactions. When you communicate with a User of Laguna Services, either directly by yourself by any means, including through chat, email, video, or by phone (including call recordings), we collect the personal information you provide us including but not limited to your name, email address, phone number, and date of birth, or other unique personal identifier to confirm your identity.

To the extent permitted by applicable law, we may tie non-personal information collected automatically to personal information about you that we collect from other sources or that you provide to us.

Information We Collect From Third Parties

Information We Collect Directly From Covered Entities or Business Associates. Your health insurance carrier may append to our Systems your contact details, medical information, and PHI.

IV. Third-Party Use of Cookies and Other Tracking Technologies

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

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

V. Third-Party Links

Our Site may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

VI. Regarding Health Information

Protected health information. In certain circumstances, we may collect or use your information through our Website and Services while acting as a Business Associate under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), which may constitute “Protected Health Information” or “PHI”. A “Business Associate” includes an entity that provides services to a HIPAA Covered Entity that involves the use or disclosure of Protected health information. A “Business Associate” includes an entity that provides services to a HIPAA Covered Entity that involves the use or disclosure of Protected health information. If your health care provider or health insurance company qualifies as a Covered Entity, and we provide services to them or on their behalf, we may qualify as their Business Associate. “Protected Health Information” or “PHI” as defined under HIPAA, generally means information about you that identifies you and that relates to your physical or mental health or condition, the provision of health care to you, or payment for health care provided to you. To the extent your PHI is collected while operating as Business Associate under HIPAA, we will only use and disclose your information as permitted by HIPAA, which may include, but not be limited to, fulfilling our service obligations, our internal management and administration, to carry out our legal responsibilities, to de-identify or aggregate data and use such de-identified data for any lawful purpose, or as otherwise required by law. If you continue to receive Services from us and sign a separate HIPAA authorization form to release your health information to us, then such health information shall no longer be subject to HIPAA and shall be subject to the terms of such authorization form.

The information we collect from you depends on how you use our Services. To the extent we collect PHI from you in any of the categories set forth below, then such PHI is subject to HIPAA, as set forth above. However, when you sign up with Laguna directly as part of our direct-to-consumer offering, (i.e. not through a Medical Provider or your insurance Company) then that information is not PHI. If your health care provider or health insurance company qualifies as a Covered Entity, and we provide services to them or on their behalf, we may qualify as their Business Associate. “Protected Health Information” or “PHI” as defined under HIPAA, generally means information about you that identifies you and that relates to your physical or mental health or condition, the provision of health care to you, or payment for health care provided to you. To the extent your PHI is collected while operating as Business Associate under HIPAA, we will only use and disclose your information as permitted by HIPAA, which may include, but not be limited to, fulfilling our service obligations, our internal management and administration, to carry out our legal responsibilities, to de-identify or aggregate data and use such de-identified data for any lawful purpose, or as otherwise required by law. If you continue to receive Services from us and sign a separate HIPAA authorization form to release your health information to us, then such health information shall no longer be subject to HIPAA and shall be subject to the terms of such authorization form.

VII. How We Use Your Information

Website:

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

To present our Website and its contents to you.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Website or any products or services we offer or provide though it.
To allow you to participate in interactive features on our Website.
In any other way we may describe when you provide the information.

Services:

For the Users of our Services, we use information that we collect about you or that you provide to us, including any personal information:

In the Provision and Improvement of Services. To provide our Services; to communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes; and to tailor the content and information that we may send or display to you, to verify your identity, to offer location customization, and to otherwise personalize your experiences while using our Services.

Communications. To send you notifications, emails, text messages, or other messages related to our Services, and to provide information about updates to our Terms of Use.
Security and Protection of Rights. To protect our Services and business operations; to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use.
For any other purpose with your consent.

For consumers, we use information that we collect about you including any personal information:

For the provision of Services to our Users for call analysis and summaries to better optimize care.

VIII. Disclosure of Your Information

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

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

To our subsidiaries and affiliates.
Third Parties. To contractors, service providers, and other third parties we use to support our business and 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. These may include, for example, IT service providers, cloud storage providers, customer support, security monitoring, marketing providers, analytics providers, and others. Where our service providers will have access to PHI, we have entered into Business Associate Agreements that govern their handling of PHI.
Successor Organizations. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Laguna Health, Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Laguna Health, Inc. about our Website users is among the assets transferred.
General Business and Operational Support. To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.

With your consent or as otherwise directed by you.

We may also disclose your personal information:

Compliance and Legal Process. To comply with the law and our legal obligations, to respond to legal processes and related to legal proceedings To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
Security and Protection of Rights. To protect our Services and business operations; to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use.
To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved.
Aggregate and De-Identified Information. We may share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, our business purposes, research or similar purposes.

IX. Choices About How We Use and Disclose Your Information

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

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
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 {OTHER OPT-OUT METHOD} or at any other time by sending us an email stating your request to {EMAIL ADDRESS}. For this opt-out to function, you must have your browser set to accept all browser cookies.
Effect of Termination of Services. Please note that terminating your use of Services will not necessarily delete Personal Information that is stored on our servers. If you wish to delete all Personal Information that we have collected about you, including PHI, please send a deletion request to connect@lagunahealth.com and we will delete your information within a reasonable timeframe. However, please note that we may be required by applicable laws and regulations to retain certain Personal Information for a longer period of time. Please note that aggregate and/or anonymous information derived use of the Services may remain on Laguna servers.
Promotional Communications: We may send periodic promotional emails to you. You have the right to opt-out of marketing messages at any time by following the instructions in such marketing messages or by contacting us at: connect@lagunahealth.com. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about any services you have requested or received from us.
Outreach. We may also call or text you to communicate with you about Services you have requested or received from us. We will obtain your consent for this type of communication upon our initial outreach. You have the option to opt out of text messages by clicking the opt-out link in our initial outreach or by replying to the text message with your communication preferences. To opt out of phone calls, you may explicitly ask us to opt-out and we will record and honor your request.

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

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

X. Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

XI. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. We take steps to ensure that any international transfer of personal information is carefully managed to protect your rights and interests and that such transfers comply with applicable data protection laws. In this regard, we only transfer your personal information outside of the country in which it was originally collected to countries which provide an adequate level of data protection similar to that of the country in which the personal information was collected or where we are satisfied that there is an appropriate justification under applicable data protection laws for the transfer. Regulatory approval for transfers will also be obtained in circumstances where required.

Please be aware that despite our best efforts, no data security measures can guarantee security.

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 Website. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on the Services via unauthorized password activity. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

XII. Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address if one is provided to us and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

XIII. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

100 Park Ave.

New York, NY 10017

privacy@lagunahealth.com