POSITION HEALTH, LLC PRIVACY POLICY

Introduction

Position Health, LLC (“Position Health, LLC”) is dedicated to protecting your personal information. This Privacy Policy applies to your use of any Position Health, LLC owned websites, software, or associated services (collectively the “Platform”). Our Privacy Policy discloses our privacy practices and explains how we use, collect, store, transfer, and share your personal information. Additionally, if you are a European user or EU citizen our Privacy Policy addresses additional rights you may have to your personal information. Please review this Privacy Policy periodically as we may revise it from time to time without notice. If you do not agree with or accept our Privacy Policy in its entirety, you must not access or use the Platform.

Information Collected

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed or otherwise anonymized.

Personal Information Collected Voluntarily Provided

You will not be required to provide us with any personal information when you visit our Platform. However, portions of our Platform may require us to collect personal information about you. During your use of the Platform we may collect your name, email, address, telephone number, username, password, identifier, company name and address, organization information, and other identifying details. Any personal information you submit via the Platform shall be used and disclosed in accordance with this Privacy Policy. We may also collect payment information that you make available to us for your use of the Platform. Please be aware that this payment information shall be stored by third-party payment processors.

Personal Information Automatically Collected

Whenever you use our Platform, we may collect non-identifying information from you, such as your IP address, interactions with the Platform, query information, location information, pricing data, research history, location and GPS information, referring URL, browser, application interaction, mobile provider information, operating system, data usage, data transferred, and Internet Service Provider.

Anonymized Data

Please be aware that we me may collect and aggregate personal information from our Platform and may anonymize that information for our own research or internal purposes. Once such data has been anonymized, it cannot be traced back to you, the user.

Sharing and Use of Your Information

This section explains how we plan on sharing and using your personal information. You consent to our use of your personal information for the following purposes:

• Contract Administration. We may use your personal information to:
  (1) negotiate, execute, renew and/or manage a contract with you;
  (2) process billing, quotes, license requests, or other information transactions and payments related thereto; and/or
  (3) communicate with you in respect of the above (including sending legal notifications).
• Access and Communications to Our Platform and Services. We may use your personal information to:
  (1) set-up and manage your Position Health, LLC account;
  (2) interact with you through our Platform (e.g. software updates, Platform announcements, etc.); and/or
  (3) manage and respond to your questions (e.g. technical, commercial or administrative) or requests for maintenance and support.
• Use of the Platform. We may use your personal information to:
  (1) enable you to enjoy the use of, and easily navigate the Platform; and/or
  (2) better understand your needs and interests. The legal basis is Art. 6(1)(f) of the EU General Data Protection Regulation (“GDPR”).
• Sharing with Third Parties. We may use your personal information to share with our partner companies or future affiliates for research, marketing, and other purposes. We may also share your information service providers with whom we contract with such as contractors, web hosts, data providers and others so that we may provide you any services and allow you to access the Platform.
• Allowing Downloads from the Platform. We may use your Personal Information to allow you download data or content from the Platform.
• Training and Improvements. We may use your personal information to:
  (1) train our employees or contractors to allow for a better Platform experience; and/or
  (2) improve the Platform.
• Direct Marketing and Inquiries. We may use your personal information to contact you for additional products and services that you may be interested in or to respond to an inquiry.
• Information Third Parties Provide About You. We may receive information from other businesses or users about you. For example, when other users submit a company inquiry or create a company profile, they may include your information in such an inquiry.
• Legal Process. We may share your information if we believe that disclosure is reasonably necessary to comply with a law, regulation, legal or governmental request; to respond to a subpoena, court order, warrant, or other legal process; to enforce applicable Terms of Service or this Privacy Policy, including investigation of potential violations thereof; to protect the safety, rights, or property of the public, any person, or Position Health, LLC; to detect, prevent, or otherwise address, security, or technical issues or illegal or suspected illegal activities (including fraud); or as evidence in litigation in which we are involved, as part of a judicial or regulatory proceeding.

Retention of Personal Information

Position Health, LLC, will only retain your Personal Information for as long as required. We will keep your personal information:

• For any legally required duration.
• Until we no longer have a valid reason to keep or use your personal information. We retain the personal information we collect for so long as reasonably necessary to fulfill the purposes for which the information was collected, to perform our contractual and legal obligations, and for any applicable statute of limitations periods for the purposes of bringing and defending claims.
• Until we receive a request to eliminate, delete, or modify any of your personal information stored with us.

Legal Basis for Processing Information

Your information collected through the Platform may be stored and processed in the United States or any other country in which Position Health, LLC or its subsidiaries, affiliates, or service providers maintain facilities. We may transfer information that we collect about you, including personal information, to affiliated entities, or to other third-parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

We process and use your personal information, where required by law, for the following purposes:

• as necessary to fulfill this Privacy Policy or our Terms of Service;
• consistent with your consent, which you can revoke at any time;
• as necessary to comply with our legal obligations;
• occasionally to protect your vital interests, or those of others;
• as necessary in the public interest; and
• as necessary for our (or others’) legitimate interests, including our interests in providing a safe and profitable services to our users and partners.

Accessing and Editing Your Information

When using our Platform you may be able to access and edit some of your personal information via the Platform dashboard. If at any time, you have any questions or wish to review, change, or edit any additional personal information collected by us, please contact us at info@positionhealthusa.com
.

Removal of Information

If you wish to have any of your personal information stored within the Position Health, LLC Platform removed, please contact us at info@positionhealthusa.com
. Please be aware that removal requests are not processed instantaneously. There may be a reasonable delay in removing any personal information requested.

You may make a removal request by email at info@positionhealthusa.com
. If you require additional details regarding the deletion or retention of your personal information, please contact us. All removal or deletion requests are subject to Section 6 and subject to any applicable laws. Additionally, we will retain and use your personal information (even after a removal or deletion request), where required, so that we may fulfill our legal obligations, resolve disputes, and enforce our agreements.

Opting Out and Do Not Track

If you decide to provide us with your contact information, you agree that we may send you communications via text and email where you have consented. However, you may opt out of any communications and you may opt out of certain personal information submission where applicable. If you wish to opt out of certain communications or information collection, please contact us at info@positionhealthusa.com
.

We currently do not offer website functionality for you to opt out of any “do not track” signals or listings.

Third Parties

Position Health, LLC may post links to third-party websites on our Platform, which may include information that we have no control over. When accessing a third-party website through our Platform, you acknowledge that you are aware that such third-party websites are not screened for privacy or security issues by us. Position Health, LLC bears no responsibility for the information collected or used by any advertiser or third-party website that you have visited through a link on our Platform. You must review that third-party’s terms of service and privacy policy to understand how their information collection and retention practices work.

Security Measures

We make reasonable attempts to protect your information by using physical and electronic safeguards in accordance with industry standards. However, as our Platform is hosted electronically, we can make no guarantees as to the security or privacy of your information. For this reason, we recommend that you use anti-virus software, routine credit checks, robust passwords, firewalls, and other precautions to protect yourself from security and privacy threats.

Your California Privacy Rights

Position Health, LLC permits residents of the State of California to use its Platform and complies with the California Business and Professions Code §§ 22575-22579. If you are a California resident, you may request certain information regarding our disclosure of personal information to any third parties for their direct marketing purposes. Various provisions throughout this Privacy Policy address requirements of the Californian privacy statutes. Although we do not disseminate your information to third parties without permission, you must presume that we collect electronic information from all Platform visitors. You may contact us at info@positionhealthusa.com
with any questions regarding your California Privacy Rights.

Age Compliance

We intend to fully comply with American and international laws respecting children’s privacy. Therefore, we do not collect or process any information for any persons under the age of 18. If you are under 18 you are prohibited from accessing the Platform.

Transfer of Your Information to the United States

Please be aware that if you are located outside of the United States, your personal information shall be transferred and processed in the United States. If you are a citizen or resident of the European Economic Area (“EEA”), Position Health, LLC shall ensure that your Personal Information shall have an adequate level of protection, which may include executing Data Protection Agreements with our processors and that process your information. These data transfers are necessary to provide the Platform to you. Where we transfer your Personal Information outside of the EEA, we may utilize standard contract clauses, the Swiss-US Privacy Shield, and other data protection mechanisms approved by the European Commission.

Merger and Acquisition

In the event that Position Health, LLC is involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal information may be sold or transferred as part of that transaction. Please be aware that once the information is transferred your privacy rights may change.

Amendments

Like our Terms of Service and Cookie Policy, we may amend this Privacy Policy from time to time. When we amend this Privacy Policy, we will modify the date listed on this Agreement or we may contact you. You must agree to the amendments as a condition of your continued use of our Platform. If you do not agree, you must immediately cease using our Platform and notify us of your refusal to agree by e-mailing us at info@positionhealthusa.com

Privacy Notice for European Citizens

Position Health, LLC respects the rights of citizens or persons living within the EEA and the rights afforded to them under the GDPR this section addresses the privileges of EEA users. If you live in a country in the EEA the services are provided by Position Health, LLC, 1316 Sherman Ave., Evanston, IL 60201 the data controller responsible for your information when you use our Platform.

Legal Rights Your Rights Under the GDPR

The right to be informed
Position Health, LLC wishes to keep you informed as to what we do with your personal information. We strive to be transparent about how we use your data.

The right to access
You have the right to access your information at any time. Please contact us at info@positionhealthusa.com
if you wish to access the personal information that Position Health, LLC holds about you.

The right to rectification
If the information Position Health, LLC holds about you is inaccurate or not complete, you have the right to ask us to rectify it. If that data has been passed to a third-party with your consent or for legal reasons, then we must also ask them to rectify the data.

The right to erasure
Sometimes called “the right to be forgotten.” You have the right to request that Position Health, LLC to erase any and all of your personal data.

The right to restrict processing
You have the right to ask Position Health, LLC to restrict how we process your data. This means we are permitted to store the data but not further process it. We will only keep enough data to ensure that we can accommodate any additional requests.

The right to data portability
Position Health, LLC must allow you to port and reuse your personal data for your own purposes across different platforms. Please contact our team at info@positionhealthusa.com
if you wish to receive additional information on how to port your data elsewhere. This right only applies to personal data that you have provided to us as a data controller.

The right to object
You have the right to object to Position Health, LLC processing your data even if our processing is due to legitimate purposes as described in our Privacy Notice.

The right to withdraw consent
If you have given us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time, and Position Health, LLC must stop processing your data. You may withdraw your consent at any time.

You may exercise these rights by contacting us at info@positionhealthusa.com
. If we process your information based on our legitimate interests or those of a third-party, or in the public interest, you can object to this processing, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons.

Contacting Us

If you have any questions email at info@positionhealthusa.com
or
Position Health, LLC
736 N Western Avenue, Suite 314
Lake Forest, IL 60045

.