Privacy Policy

Introduction

Brello, LLC on its own behalf and on behalf of its affiliates and contractors (collectively "we," "us," or "our") are committed to protecting the privacy of our visitors and users, and providing them with detailed information as to how their information is used and protected. This Privacy Policy describes how we collect and process your personal information through our website and services (together, the "Services").

This Privacy Policy is incorporated into our Terms of Use. By using our Services, you consent to the practices described in this Privacy Policy and you agree that your personal information will be handled as described in this Privacy Policy. If you do not agree with this Privacy Policy, do not access or use the Services.

Scope of this Privacy Policy and Protected Health Information

This Privacy Policy describes the types of Personal Information we collect from visitors to our website and users of our Services, as well as our practices for using, maintaining, sharing, and protecting it. It also describes the rights and choices you may have with respect to your Personal Information and how we can be contacted.

This Privacy Policy does not apply to information collected from you if you register and log-in to the password-protected and secure portions of our Services (the "Platform"), which are intended for potential patients of independent healthcare providers. All information collected within the Platform is considered Protected Health Information ("PHI") and/or personal data governed by applicable state and federal laws, including HIPAA. To understand how we use and disclose PHI, review our Notice of Privacy Policies, available to users within the Platform.

01.Types of Personal Information We Collect

While using our Services, you may provide us with certain information about you. We or our advertising partners may also automatically collect information through cookies and other tracking technologies.

Personal Information collected through your use of the Services may include your IP address, device ID, online identifiers (e.g., login credentials), and device location. We may also use device identifiers, cookies, web beacons, tokens, scripts, and similar technologies to collect information about your browsing patterns and devices.

We may also receive information you disclose through forms or surveys, or when you sign up for a user account — including your name, email address, phone number, gender, date of birth, address, payment or financial information, and other information.

02.How We Collect Personal Information

We may collect Personal Information using the following methods:

• Directly From You — when you enter information into forms, inquiries, responses, or surveys.
• Automatically — through tracking technologies such as cookies, web beacons, and log files, including over time and across our own and third-party websites.
• From Third-Party Sources — including advertisers, ad networks, analytics companies, your mobile device manufacturer or service provider, social media services you connect through, publicly available sources, and service providers acting on our behalf.

03.How We Use Your Information

We collect your information to provide and improve our Services. We may disclose deidentified and anonymized information for research or commercial purposes, except for payment and financial information and information prohibited by law from disclosure.

Information obtained directly from you may be used for:

• Conducting internal research and making business decisions about product and Service offerings;
• Responding to your comments, questions, and requests, and providing customer service;
• Communicating with you about products, services, offers, promotions, and events;
• Managing your online account and sending technical notices, updates, security alerts, and administrative messages;
• Personalizing your online experience and providing content or features that match your interests;
• Monitoring and analyzing trends, usage, and activities;
• Aggregating information for analytics and reporting;
• Responding to law enforcement requests, court orders, and legal process, and carrying out our legal and contractual obligations;
• Enforcing our Terms of Use;
• Fulfilling any other purpose for which you provided the information.

04.How We Share Collected Information

We may share your personal information with our affiliates, partners, and other third-parties, including subcontractors, for certain purposes:

• Business Purposes — with data hosting/storage partners, analytics and advertising partners, technology support, and data security providers.
• During a Transaction — with a buyer or successor entity in the event of a merger, restructuring, sale of assets, or similar proceeding.
• Compliance With Law — to comply with any court order, law, or legal process, including responding to regulatory requests.
• Other Reasons — to ensure the safety and security of our Services and protect our, our customers', or others' rights, property, or safety.

05.Third-Party Websites and Collected Information

When you use the Services, certain third-parties may use automatic information collection technologies to collect information about you or your device. This Privacy Policy does not address, and we are not responsible for, the privacy Policies of any third-parties, including physicians and other healthcare providers using the Services.

Our website may contain links to other online platforms operated by third parties. We do not control such platforms and are not responsible for their content, privacy policies, or use of your information. Information you provide on public or semi-public venues may be viewable by other users without limitation.

06.Cookies and Information Used for Advertising

We may collect and disclose personal information about your online activities to provide advertising tailored to your interests. Ad networks allow us to target messaging through demographic, interest-based, and contextual means, tracking online activities via cookies, web server logs, and web beacons.

You may disable or delete browser cookies through your browser settings. If you delete or disable cookies, some parts of our websites may not work properly.

07.Privacy and Security

We design our systems with your security and privacy in mind, and maintain administrative, technical, and physical safeguards to protect your personal information.

The safety of your information also depends on you. Where we have given you a password for access, you are responsible for keeping it confidential.

Transmission of information via the internet is not completely secure. We cannot guarantee the security of your personal information transmitted through our website; any transmission is at your own risk.

08.Notification of Changes

We reserve the right to change this Privacy Policy from time to time in our sole discretion. Your continued use of our Services indicates your consent to the Privacy Policy as posted. If we make material changes, we will notify you by email or through a notice on our website.

09.Accessing/Deleting Your Personal Information

You may be able to update, correct, or delete your personal information by contacting us. We may not be able to delete your information without also deleting your account, and may not accommodate a request that would violate any law or cause information to become incorrect.

10.Retention of Your Information

We keep your information for no longer than necessary for the purposes for which it is processed. Retention depends on the purposes for which we collected the information and applicable laws.

11.Children Under 13

Our Services are not intended for children under 13 years of age. We do not knowingly collect personally identifiable information from children under 13 without parental consent. If we learn we have collected such information without parental consent, we will delete it.

12.Your State Privacy Rights

Certain states afford their residents additional rights with respect to their personal information. You may have the right to:

• Opt out of the processing of your personal data for targeted advertising, sale of personal data, and/or profiling that produces legal or significant effects on you;
• Opt out of the processing of sensitive data, including geolocation data;
• Opt out of the collection of personal data through voice or facial recognition features;
• Access your data and confirm whether we have collected, held, or processed it;
• Obtain a list of third-parties to which we have disclosed your personal data;
• Delete personal data we have collected about you;
• Correct inaccuracies in your personal data;
• Receive your requested data in a portable, transferable form;
• Non-discrimination or retaliation for exercising any of these rights.

Responding to Requests

We are required to respond to your requests without undue delay but within forty-five (45) days of receipt. We may extend the time for response once for an additional fifteen (15) days.

If we decline to take action, we must notify you within forty-five (45) days and provide information on our appeal process.

You can request information free of charge twice per year. For a third or subsequent request within a 12-month period, we reserve the right to charge a fee.

How to Exercise Your Rights

If you would like to exercise any of your rights, you can do so through our website or by emailing info@brellohealth.com. If your request is declined, you may appeal the decision by contacting us.

If you contact us by email, you will need to provide: enough information to identify you (e.g., full name, address, reference number), proof of your identity and address, and a description of the right you want to exercise. Personal data collected for verification will be used solely for that purpose.