Lab Me Analytics Privacy Policy

Protecting your privacy and personal health

Overview

Lab Me Analytics (“we”, “us” or “our”) is committed to protecting and respecting your privacy.

This privacy statement (“Privacy Statement”), together with our Cookies Policy, describes the types of personal information collected and created in connection with your use of our Products and Services, how and why we use such information, who we share it with, and your legal rights. Please read the following carefully to ascertain how we process your personal information (or “information”).

We may, from time to time, provide links on www.labme.ai  (the “Site”) to the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy statements and that we do not accept any responsibility or liability for their privacy or security practices. Please check these privacy statements before you submit any personal information to these websites.

For residents of the United Kingdom and the European Economic Area (the “EEA”), the service provider and the controller of your information is LAB ME ANALYTICS PTE. LTD., trading as Lab Me Analytics, registration number UEN: 201806651M and registered office at 6 RAFFLES QUAY #11-07 SINGAPORE 048580

For residents of the US and non-EEA countries, the service provider is LAB ME ANALYTICS PTE. LTD.., a Singapore corporation assigned number UEN: 201806651M and registered office at 6 RAFFLES QUAY #11-07 SINGAPORE 048580. Lab Me Analytics is an Incorporation of Local Company Transaction No.: C180105550

Any defined terms in the Terms of Use shall have the same meaning when used in this Privacy Statement.

What information we collect

When you access the Site or use our Products and Services, we collect, receive or otherwise process information in several different ways. In many cases, you choose what information to provide. Some information is required in order for us to provide our Products and Services. We use your information for the purposes described further below.

We may collect and process the following types of information about you:

  1. Purchase and assistance information. We collect information when you purchase our Products and Services, including when you phone our Support Team. This information will include name, gender, contact information, billing address, delivery address and any further information you volunteer to provide through the Site.
  2. Health-related data. When you purchase or use our Products and Services, we will collect and process data concerning health, including Samples, Test Information or any further information we might receive from Accredited Laboratories. When you activate a Service or Product, we will collect and process information relating to your personal health record as well as a suitability questionnaire to confirm that the Service or Product is appropriate to your needs. You may also provide information to us if you connect a wearable device to one of our Products or Services.
  3. Correspondence. We will collect and maintain your contact details when you communicate with us, sign up for promotional material, participate in special promotions, or connect with us through social media. If you contact us by email, we may keep a record of that correspondence.
  4. Website and device information. We collect information about your browser or device, including, where available, your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. We also collect details of your visits to our Site including, but not limited to, traffic data, location data, the resources that you access, web logs and other communication data. Our Site also uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. For detailed information on the cookies we use and the purposes for which we use them, see our Cookies Policy. We may also ask you for information when you report a problem with our Site.
  5. Survey information. If you respond to any surveys that we might request, which are completely voluntary, we will process your responses.

How we use your information

We use the information we have to help us provide, operate, improve, understand, customize, support, and market our Products and Services. The broad uses of your information are described below. As required under Singaporian law, we have also specified the legal bases which we rely on to process your information.

We rely on your explicit consent to process your information as follows:

  • To receive, store and analyse your Samples at Accredited Laboratories.
  • To receive, review, store and communicate your Test Information to you, including by presenting your Test Information and other reported history via the Lab Me Analytics secure environment.
  • To provide you with your results and, in some instances, relevant treatment options.
  • To de-personalise your information for service improvement, product quality improvement and/or research, as relevant.

You can withdraw your consent to this processing at any time. Withdrawing your consent stops future processing and does not affect any processing we have already undertaken. Without your consent, however, we shall be unable to provide most of our Products and Services to you.

To fulfil our contract(s) with you, we process your information – including data concerning your health and medical history – as follows:

  • To fill and support your purchases of our Products and Services, including to process payments and to provide customer assistance.

It is in our legitimate interests to process your information as follows:

  • To ensure that content from our Site is presented in the most effective manner for you and your device.
  • To contact you with offers, updates and news related to Services and Products you have purchased, unless you choose not to receive these.
  • To analyse non-health information provided by you and others to help us administer, support and improve our business.
  • To detect, investigate and prevent activities that may violate our policies or agreements or be illegal, including by sharing information with law enforcement.

We are legally obligated to process your information as follows:

  • To retain certain records about the handling of any Samples you send us for regulatory purposes.
  • To retain certain tax and accounting records.

Children’s privacy

We will not knowingly collect personal information from Site users that are under 18 years of age. We are relying on your undertaking in the Terms of Use that you are over 18 years of age. You should not use the Site or its Services, including purchase Products, if you are not 18 years of age or older. If you believe we might have information from or about an individual under 18 years of age, please contact us at .

Where we store your information

The information that we collect from you may be transferred to and stored with an Accredited Laboratory (as defined in the Terms of Use) or any supplier of data processing and data hosting services to us at, a destination within the EEA. It may also be processed by staff operating inside the EEA who work for any of them. Such staff may be engaged in, among other things, the fulfilment of your order, the provision of data processing and data hosting services to us.

In certain cases, we transfer and store certain information outside the EEA, such as to the United States. In such cases, we use a legal mechanism known as “standard contractual clauses” to protect information transferred outside the EEA. Standard contractual clauses refer to contracts between companies transferring personal information that contain standard commitments, approved by the European Commission, protecting the privacy and security of the information transferred. To request a copy of the clauses, please email us at email us

How we secure your information

All information you provide to us in purchasing or availing of our Products or Services are stored on our secure servers or else on secure servers used by our service provider. Any payment transactions effected by us will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. You must not share a password with anyone.

Unfortunately, the transmission of information via the internet is not secure and if you request that we communicate with you using a secure means of communication, we can arrange to do this. Once we have received your information, we will impose obligations of confidentiality and security on any of our service providers who process the information.

We maintain appropriate physical, electronic, standard security practices, including encryption, passwords and physical security measures, and managerial procedures to protect the security and confidentiality of your personal data. Only a limited number of our internal staff are authorised to access, delete or modify your data. We will make reasonable efforts to ensure that your privacy interests are protected.

Disclosure of your information

We share information with service providers, affiliates, partners, and other third parties where it is necessary to provide the Products and Services, or for any other purposes described in this Privacy Statement. In particular, we may share your information with certain third party suppliers and service providers to help us operate, provide, improve, understand, customize, support, and market our Products and Services. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Statement by imposing obligations of security and confidentiality on such service providers.

Your information may be provided as necessary to following categories of recipients: Accredited Laboratories, couriers, communications and marketing service providers, analytics providers, legal or financial advisors, or government/regulatory/law enforcement agencies pursuant to legally binding order.

We may disclose and transfer your information to our Accredited Laboratory for the purpose of (i) accepting and processing an accepted order by us, (ii) in order to procure the Product is delivered to you by it, and (iii) to test any Sample provided and make your Test Information available to you on our secure Account on our Site.

To process a request for a Product and for our Accredited Laboratory to test the Sample and send you the Test Information, we need to disclose information within our company including to the Medical Practitioner, to our Accredited Laboratory and our IT services providers. Your request for a Product will result in your order details being accessed by and processed by our Accredited Laboratory and our IT service providers.

The Accredited Laboratory shall have access to: your date of birth, your Sample, information relevant to your test (i.e. gender), and the test results created therein, in a pseudonymised manner that cannot be attributed to you without the use of additional information kept separately in our database. The Accredited Laboratory shall not have access to your other personal information.

In instances where our business is subject to a reorganization, such as a merger or acquisition of some or all of its assets, we may, in accordance with our legitimate interests, need to share information in the course of the transaction. In such circumstances, your information may be disclosed, where permitted by applicable law, in connection with a corporate restructuring, sale, or assignment of assets, merger, or other changes of control or financial status of Lab Me Analytics.

If you send offensive or objectionable content or otherwise engage in any disruptive behaviour on the Site, we can use your information to stop such behaviour and pursue our legitimate interest to prevent such behaviour on our Site. This may involve informing relevant third parties, such as law enforcement agencies about the content and your behaviour.

Equally, we may retain, preserve, or disclose your information if we have a good-faith belief that it is reasonably necessary to (i) respond, based on applicable law, to a legal request (such as a subpoena, a search warrant, court order, or other request from government or law enforcement); (b) detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; (c) protect our rights, property, or safety; (d) enforce the agreements we have with you; (e) prevent physical injury or other harm to any person or entity, including yourself and members of the general public. For example, your IP address may be supplied to regulatory authorities in connection with fraud or other formal investigations.

We may pass aggregate information on the usage of our Site to third parties, but this will not include information that can be used to identify you. Unless required to do so by law, we will not otherwise share sell or distribute any of the information you provide to us without your consent.

How long do we keep your information?

We retain your information in our server logs, our databases, and our records for as long as necessary to provide the Products and Services. We may need to retain some of your information for a longer period, such as in order to comply with our legal or regulatory obligations, to resolve disputes or defend against legal claims, or to enforce our Terms of Use.

Your rights

If you live in the EEA, you have certain rights in relation to your information that we process. While some of these rights apply generally, others apply only in certain circumstances. To exercise your rights or to submit a question, you can email us.

  • Access. You have the right to request a copy of your information that we process. You may exercise this right in the “privacy settings” section in your user account. If you require additional access, please email us.
  • Correction. If you discover that we hold inaccurate information about you, you have a right to ask us to correct that information. You can correct account information by logging into your account. For other corrections, please email us.
  • Erasure. You have the right to request that we delete your information. We may refuse this request if (a) the information is still necessary for the purposes that we collected or processed it or (b) we still have a legal basis to process it, even after you’ve withdrawn consent. You can exercise this right in the “Privacy Settings” section of your user account or you can email us.
  • Restriction. You have the right, in some cases, to restrict the processing of your information, such as where you have exercised your right to object and we are reviewing your objection. For more information, please email us.
  • Objection. You have the right to object to us using your information based on our legitimate interests described above. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your data for direct marketing, you can always object by using the unsubscribe link in such communications, changing your account settings or, if you do not have an account, you can email us.
  • Portability. You have the right in some cases to port your information from us to a new data controller. We can refuse this request if (a) our processing is not based on your consent or our contract with you, or (b) the data are not stored electronically. You can exercise this right through the “Privacy Settings” section in your user account to download your data in XML format. Alternatively, you can email us.
  • Withdraw consent. You can withdraw your consent to the processing at any time by deactivating your account through the Lab Me Analytics website or by e-mailing. Withdrawing your consent does not affect the processing that has already occurred. Where you withdraw your consent, we will no longer process your information based on your consent. We may process your information if another legal basis applies, for example, if we are legally obligated to store certain records or if your withdrawal of consent was limited to certain processing activities.
  • Complain. You have the right to lodge a complaint with our lead supervisory authority – the Data Protection Commission (www.dataprotection.ie) – or the data protection supervisory authority for your EEA jurisdiction. If you are considering lodging a complaint, we would appreciate the opportunity to try and resolve your issue before you submit your complaint.
 

Changes

FULL PRIVACY POLICY FOR LAB Me’s Telehealth Partner Beluga Health.
Version 1

WE AT BELUGA HEALTH, P.A. (“We”, “Us”, or “Beluga”) VALUE YOUR PRIVACY AND ARE COMMITTED TO
KEEPING YOUR (“You/Your”) PERSONAL DATA CONFIDENTIAL. WE USE YOUR DATA SOLELY IN THE
CONTEXT OF PROVIDING A WEB PORTAL (“WEB PORTAL”) AND VARIOUS RELATED SERVICES DEFINED
BELOW (“SERVICES”) TO SUPPORT THE DELIVERY OF REMOTE CLINICAL CARE AND PRESCRIPTION
SERVICES BY QUALIFIED PHYSICIANS (“PROVIDER USERS”) TO PATIENTS OF BELUGA HEALTH (“PATIENT
USERS”). YOU ARE EITHER A PATIENT-USER OR A PROVIDER USER. THE SERVICES INCLUDE, IN ADDITION
TO THE WEB PORTAL, THE FACILITATION OF (1) SECURE INFORMATION COLLECTION, (2) SHORT MESSAGE
SERVICE (“SMS”) AND MULTIMEDIA MESSAGING SERVICE (“MMS”) COMMUNICATIONS BETWEEN
PATIENTS AND PROVIDERS, AND (3) ELECTRONIC PRESCRIBING OF MEDICATIONS.

THIS PRIVACY POLICY APPLIES TO PERSONAL DATA BELUGA COLLECTS FROM USERS OF THE SERVICES.
“PERSONAL DATA” INCLUDES ANY INFORMATION THAT CAN BE USED ON ITS OWN OR WITH OTHER
INFORMATION IN COMBINATION TO IDENTIFY OR CONTACT ONE OF OUR PATIENTS OR PROVIDER
USERS. WE BELIEVE THAT TRANSPARENCY ABOUT THE USE OF YOUR PERSONAL INFORMATION IS OF
UTMOST IMPORTANCE. IN THIS PRIVACY POLICY, WE PROVIDE YOU WITH DETAILED INFORMATION ABOUT OUR
COLLECTION, USE, MAINTENANCE, AND DISCLOSURE OF YOUR PERSONAL DATA. 
 
THE POLICY EXPLAINS WHAT KIND OF INFORMATION WE COLLECT, WHEN AND HOW WE MIGHT USE THAT INFORMATION, HOW
WE PROTECT THE INFORMATION, AND YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION.

SOME OF THE PERSONAL DATA WE COLLECT AND TRANSMIT WILL, IN SOME CIRCUMSTANCES, BE
CONSIDERED “HEALTH DATA” (data related to a Patient User’s physical or mental health) or “Protected
Health Information” (information that relates to the past, present, or future physical or mental health or
condition of a Patient User; the provision of health care to a Patient User; or the past, present, or future
payment for the provision of health care to a Patient User). THEREFORE, OUR PRIVACY PRACTICES ARE
INTENDED TO COMPLY WITH THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (“HIPAA“)
AND WITH STATE LAW RELATED TO HEALTH DATA, WHERE APPLICABLE. FOR ADDITIONAL INFORMATION
RELATED TO YOUR HEALTHCARE INFORMATION, PLEASE CONTACT OUR PRIVACY OFFICER AT
security@belugahealth.com.

BY SUBMITTING YOUR PERSONAL DATA THROUGH THIS WEB PORTAL OR THROUGH THE SERVICES, YOU
ARE ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS POLICY. IF YOU DO
NOT AGREE, PLEASE DO NOT LOG INTO OR ACCESS THE WEB PORTAL AND DO NOT SUBMIT ANY
PERSONAL DATA TO US.

PLEASE NOTE THAT WE OCCASIONALLY UPDATE THIS PRIVACY POLICY AND THAT IT IS YOUR
RESPONSIBILITY TO STAY UP TO DATE WITH ANY AMENDED VERSIONS. IF WE MODIFY THE PRIVACY
POLICY, WE WILL POST A LINK TO THE MODIFIED TERMS ON THE WEB PORTAL AND WILL ALSO NOTIFY
YOU VIA EMAIL. YOU CAN STORE THIS POLICY AND/OR ANY AMENDED VERSION(S) DIGITALLY, PRINT IT,
OR SAVE IT IN ANY OTHER WAY. ANY CHANGES TO THIS PRIVACY POLICY WILL BE EFFECTIVE IMMEDIATELY
UPON PROVIDING NOTICE, AND SHALL APPLY TO ALL INFORMATION WE MAINTAIN, USE, AND DISCLOSE.
IF YOU CONTINUE TO USE THE SERVICES FOLLOWING SUCH NOTICE, YOU ARE AGREEING TO THOSE
CHANGES.

In case You have any questions or concerns after reading this Privacy Policy, please do not hesitate to
contact Us at admin@belugahealth.com. We appreciate Your feedback. If You do not agree or no longer
agree to the processing of Personal Data as described in this Privacy Policy, You can delete Your account
or request Beluga terminate the processing of your Personal Data by notifying Us by email at
admin@belugahealth.com.

Responsible Entity
Beluga is the controller of Your Personal Data and may process Personal Data in accordance with the
Privacy Policy. If We are processing Personal Data on behalf of a third party that is not an agent or affiliate
of Beluga, the terms of this Privacy Policy do not apply—instead, the terms of that third party’s privacy
policy will apply. You can contact Us with any questions about Our Privacy Policy at
admin@belugahealth.com.

What Personal Data do We collect?
The types of Personal Data We collect are described below.

Demographic Data
We collect demographic information, such as Your name, birth year, gender, phone number, and e-mail
address. Primarily, the collection of Your Personal Data assists us in creating Your account (“User
Account”) if You are a Provider User, which You can use to securely receive the Services. If You are a
Patient User, the collection of Your Personal Data assists us in securely providing you with the Services.

Payment Data
If you make payments via our Services, We may require that You provide to Us Your financial and billing
information, such as billing name and address, credit card number or bank account information.

For Patient Users: Health Data
In addition to demographic information, We will collect information regarding Your health conditions,
allergies, medical history, symptoms, and communications between You and the Provider User providing
healthcare services to You via the Services. We collect this information to provide You with the Services.

Support Data
If You contact Us for support or to lodge a complaint, We may collect technical or other information from
You through log files and other technologies, some of which may qualify as Personal Data. (e.g., Internet
Protocol (“IP”) address). Such information will be used for the purposes of troubleshooting, customer
support, software updates, and improvement of the Services in accordance with this Privacy Policy. Calls
with Beluga may be recorded or monitored for training, quality assurance, customer service, and
reference purposes.

For Provider Users: Device, Telephone, and ISP Data
We use common information-gathering tools, such as log files, cookies, web beacons, and similar
technologies to automatically collect information, which may contain Personal Data, from Your computer
as You navigate Our Services, or interact with emails We have sent You. 
 
The information We collect may include Your IP address (or proxy server), device and application identification numbers, location, browser
type, Internet service provider and/or mobile carrier, the pages, and files You viewed, Your searches, Your
operating system and system configuration information, and date/time stamps associated with Your
usage. This information is used to analyze overall trends, to help Us provide and improve Our Services and
to guarantee their security and continued proper functioning.

How will We use Your Personal Data?
We process Your Personal Data for purposes based on legitimate business interests, the fulfillment of Our
Services to You, compliance with Our legal obligations, and/or Your consent. We only use or disclose Your
Personal Data when it is legally mandated or where it is necessary to fulfill the purposes described herein.
Where required by law, We will ask for Your prior consent before using or disclosing Personal Data.

Specifically, We process Your Personal Data for the following legitimate business purposes:
● To fulfill Our obligations to You under the Terms of Use (for Provider Users);
● To communicate with You about and manage Your User Account (for Provider Users);
● To properly store and track Your data within Our system;
● To respond to lawful requests from public and government authorities, and to comply with
applicable state/federal law, including cooperation with judicial proceedings or court orders;
● To protect Our rights, privacy, safety, or property, and/or that of You or others by providing
proper notices, pursuing available legal remedies, and acting to limit Our damages;
● To handle technical support and other requests from You;
● To enforce and ensure Your compliance with Our Terms of Use or the terms of any other
applicable services agreement We have with You;
● To manage and improve the Services, including the development of additional functionality;
● To manage payment processing;
● To evaluate the quality of service You receive, identify usage trends, and thereby improve Your
user experience;
● To keep Our Services safe and secure for You and for Us;
● To send You information about changes to Our terms, conditions, and policies;
● To allow Us to pursue available remedies or limit the damages that We may sustain; and
● If applicable, to provide access to the authorized Provider User/caregiver (with Your consent), to
enable that individual to monitor Your progress and overall condition and to follow up with You,
as they deem appropriate.

Where is Your Personal Data processed?
Personal Data Beluga collects through the Services will be stored on secure servers in the United States.
Personal Data may be transmitted to third parties, which parties may store or maintain the data on their
secure servers on Our behalf. These third parties are not permitted to transfer Your Personal Data outside
of the United States.

Will We share Your Personal Data with anyone else?
For Patient Users: Yes, with the Provider User with whom You connect via the Services.
We will share information you provide to Us via the Services with the Provider User with whom connect
via the Services. If, at any point, you want to deny access to one or more Provider Users, you can do so by
emailing admin@belugahealth.com.

Yes, with third parties that help us power Our Services
Beluga has a limited number of service providers and other third parties (“Business Partners”) that help

We run various aspects of Our business. These Business Partners are contractually bound to protect Your
Personal Data and to use it only for the limited purpose(s) for which it is shared with Us. Business Partners’
use of Personal Data may include, but is not limited to, the provision of services such as data hosting, IT
services, customer service, and payment processing.

Yes, with third parties and the government when legal or enforcement issues arise
We may share Your Personal Data, if reasonable and necessary, to (i) comply with legal processes or
enforceable governmental requests, or as otherwise required by law; (ii) cooperate with third parties in
investigating acts in violation of this Agreement; or (iii) bring legal action against someone who may be
violating the Terms of Use or who may be causing intentional or unintentional injury or interference to
the rights or property of Beluga or any third party, including other users.

Yes, with third parties that provide advisory services
We may share Your Personal Data with Our lawyers, auditors, accountants, or banks when We have a
legitimate business interest in doing so.

Yes, with third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer,
or other disposition of all or any portion of Beluga’s corporate entity, assets, or stock (including in
connection with any bankruptcy or similar proceedings)

If We share Your Personal Data with a third party other than as provided above, You will be notified at the
time of data collection or transfer, and You will have the option of not permitting the transfer.

How long do We retain Personal Data?
We will retain Your Personal Data for as long as You maintain a User Account or use Our Services and up
to five (5) years after the account is closed or Services are terminated. The exact period of retention will
depend on the type of Personal Data, Our contractual obligation to You, and applicable law. We keep Your
Personal Data for as long as necessary to fulfill the purpose for which it was collected, unless otherwise
required or necessary pursuant to a legitimate business purpose outlined herein. 
 
At the end of the applicable retention period, We will remove Your Personal Data from Our databases and will request that
Our Business Partners remove Your Personal Data from their databases. If there is any data that We are
unable, for technical reasons, to delete entirely from Our systems, We will put in place appropriate
measures to prevent any further processing of such data. We retain anonymized data indefinitely.

NOTE: Once We disclose Your Personal Data to third parties, We may not be able to access that Personal
Data any longer and cannot force the deletion or modification of any such information by the parties to
whom We have made those disclosures. 
 
Written requests for deletion of Personal Data other than as
described should be directed to admin@belugahealth.com.

For Provider Users: What is Our Cookie Policy?
Cookies are small files that a Web server sends to Your computer or device when You visit a web site
that uses cookies to keep track of Your activity on that site. Cookies hold a small amount of data specific
to that web site, which can later be used to help remember information You enter into the web site (like
Your email or other contact info), preferences selected, and movement within the site. If You return to a
previously visited website (and Your browser has cookies enabled), the website sends the small file to
the Web server, which tells it what activity You engaged in the last time You used the website, and the server can use the cookie to do things like expedite logging in and retrieving user data and keeping Your
browser session secure.

We use essential cookies to provide user authentication. and other technologies to, among other things,
better serve You with more tailored information, and facilitate efficient and secure access to the
Services. We only use essential cookies. Essential cookies are those necessary for Us to provide Services
to You.

We may also collect information using pixel tags, Web beacons, clear GIFs, or other similar technologies.
These may be used in connection with some Web Portal pages and HTML-formatted email messages to,
among other things, track the actions of users and email recipients and compile statistics about usage
and response rates.

For Provider Users: How can You “Opt-Out” of Cookies?
If You prefer, You can usually choose to set Your browser to remove cookies and reject cookies. If You
enable a do not track (“DNT”) signal or otherwise configure Your browser to prevent Beluga from collecting any cookies, You will no longer be able to access the Web Portal.

How do We protect Your Personal Data?
Beluga is committed to protecting the security and confidentiality of Your Personal Data. We use a
combination of reasonable physical, technical, and administrative security controls to maintain the
security and integrity of Your Personal Data, to protect against any anticipated threats or hazards to the
security or integrity of such information, and to protect against unauthorized access to or use of such
information in Our possession or control that could result in substantial harm or inconvenience to You.

However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100%
secure. As a result, We cannot ensure the security of information You transmit to Us. By using the Services,
You are assuming this risk.

Safeguards
The information collected by Beluga and stored on secure servers, is protected by a combination of
technical, administrative, and physical security safeguards, such as authentication, encryption, backups,
and access controls. If Beluga learns of a security concern, We may attempt to notify You and provide
information on protective steps, if available, through the e-mail address that You have provided to Us or
the phone number you have provided Depending on where You live, You may have a legal right to receive
such notices in writing.

You are solely responsible for protecting information entered or generated via the Services that are stored
on Your device and/or removable device storage. Beluga has no access to or control over Your device’s
security settings, and it is up to You to implement any device-level security features and protections You
feel are appropriate (e.g., password protection, encryption, remote wipe capability, etc.). We recommend
that You take any and all appropriate steps to secure any device that You use to access Our Services.

NOTWITHSTANDING ANY OF THE STEPS TAKEN BY US, IT IS NOT POSSIBLE TO GUARANTEE THE SECURITY
OR INTEGRITY OF DATA TRANSMITTED OVER THE INTERNET. THERE IS NO GUARANTEE THAT YOUR
PERSONAL DATA WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED DESPITE THE
IMPLEMENTATION OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. THEREFORE, WE
DO NOT AND CAN NOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY PERSONAL DATA YOU
TRANSMIT TO US AND YOU TRANSMIT SUCH PERSONAL DATA AT YOUR OWN RISK.

How can You Protect Your Personal Data?
In addition to securing Your device, as discussed above, We will NEVER send You an e-mail requesting
confidential information such as account numbers, usernames, passwords, or social security numbers,
and You should NEVER respond to any e-mail requesting such information. If You receive such an e-mail
purportedly from Beluga, DO NOT RESPOND to the e-mail and DO NOT click on any links and/or open any
attachments in the e-mail, and notify Beluga support at admin@belugahealth.com.

For Provider Users: You are responsible for taking reasonable precautions to protect Your user ID,
password, and other User Account information from disclosure to third parties, and You are not permitted
to circumvent the use of required encryption technologies. You should immediately notify Beluga at
admin@belugahealth.com if You know of or suspect any unauthorized use or disclosure of Your user ID,
password, and/or other User Account information, or any other security concern.

Your rights

You have certain rights relating to Your Personal Data, subject to local data protection laws. These rights
may include:
● to access Your Personal Data held by Us;
● to erase/delete Your Personal Data, to the extent permitted or required by applicable data
protection laws;
● to receive communications related to the processing of Your personal data that are concise,
transparent, intelligible, and easily accessible;
● to restrict the processing of Your Personal Data to the extent permitted by law (while We verify
or investigate Your concerns with this information, for example);
● to object to the further processing of Your Personal Data, including the right to object to
marketing;
● to request that Your Personal Data be transferred to a third party, if possible;
● to receive Your Personal Data in a structured, commonly used, and machine-readable format;
● to lodge a complaint with a supervisory authority;
● to rectify inaccurate Personal Data and, taking into account the purpose of processing the
Personal Data, ensure it is complete; and
● to not be subject to a decision based solely on automated processing, including profiling, which
produces legal effects (“Automated Decision-Making”).

Where the processing of Your Personal Data by Beluga is based on consent, You have the right to withdraw
that consent without detriment at any time or to exercise any of the rights listed above by emailing Beluga
at admin@belugahealth.com.

How can You update, correct, or delete Personal Telehealth Data Via Beluga?

You can change Your e-mail address and other contact information by contacting
admin@belugahealth.com. If You are a Provider User, and You need to make changes or corrections to
other information, You may change your password within the account settings on the Web Portal
dashboard. Please note that in order to comply with certain requests to limit the use of Your Personal Data,
We may need to terminate Your account and/or Your ability to access and use the Services, and You agree
that We will not be liable to You for such termination or for any refunds of prepaid fees paid by You. You
can deactivate Your account or request termination of Services by contacting admin@belugahealth.com.
Although We will use reasonable efforts to do so, You understand that it may not be technologically
possible to remove from Our systems every record of Your Personal Data. The need to back up Our
systems to protect information from inadvertent loss means a copy of Your Personal Data may exist in a
non­erasable form that will be difficult or impossible for Us to locate or remove.

Can You “OPT­OUT” of receiving communications from Beluga?
We pledge not to market third-party services to You without Your consent. We may send e-mails to You
regarding Your Beluga account and/or services. You can choose to filter these account and services e­mails
using Your e-mail client settings or, if you are a Patient User, by emailing admin@belugahealth.com, but
We do not provide an option for You to opt-out of these e-mails.

Information submission by minors
We do not knowingly collect Personal Data from individuals under the age of 18 and the Services are not
directed to individuals under the age of 13. We request that these individuals not provide Personal Data
to Us. If We learn that Personal Data from users less than 18 years of age has been collected, We will
deactivate the account and take reasonable measures to promptly delete such data from Our records. If
You are aware of a user under the age of 13 using the Services, please contact Us at
admin@belugahealth.com.

If You are a resident of California, under the age of 18 and have registered for an account with Us, You
may ask Us to remove content or information that You have posted to Our Services.

California Residents
California residents may request and obtain from Us, once a year, free of charge, a list of third parties, if
any, to which We disclosed their Personal Data for direct marketing purposes during the preceding
calendar year and the categories of Personal Data shared with those third parties. If You are a California
resident and wish to obtain that information, please submit Your request by sending Us an email at
admin@belugahealth.com with “California Privacy Rights” in the subject line.

Contact Us
If You have any questions about this Privacy Policy, please contact Us by email at
admin@belugahealth.com or please write to: Beluga Health, P.A., 3225 McLeod Drive, Suite 100, Las
Vegas, NV 89121. 
 
Please note that email communications are not always secure; so please do not include
sensitive information in Your emails to Us.
 

Changes to our Privacy Statement

From time to time, we will make changes to this Privacy Statement. Any changes we may make in future will be posted on this page. If we materially change our Privacy Statement, we will take steps to notify you, for example by emailing you or by posting a notice on the Site.

Contact us

Questions, comments and requests regarding this Privacy Statement are welcomed and should be addressed to our Data Protection Officer (DPO) at support@labme.atlassian.net.

 

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