Clinic Privacy Notice

Neko Health Clinic Privacy Notice

• What is Neko Clinic?
• To What Information Does this Notice Apply?
• How We May Use and Disclose Your Information
• Your Choices Regarding Your Information
• Your Information Rights
• Changes to this Notice
• Complaints
• Contact Information

• Device and Browsing Information. When you use our Services, we and third-party providers may collect browser type, domain name, page views, access times, date/time stamps, operating system, language, device type, unique ID, Internet service provider, referring and exiting URLs, clickstream data, and other similar device and browsing information.
• Activities and Usage. We also may collect activity information related to your use of the Services, such as information about the links and buttons clicked, searches, features used, items viewed, time spent within the Services, your interactions with us within the Services, and other similar activities and usage information.
• Location Information. We also may collect or derive general location information about you, such as through your IP address.

• Treatment: We may use your personal information to provide you with medical treatment (including, for example, conducting Body Scans, laboratory testing, physical and biometric measurements, drafting medical reports and comparing different versions of your scans) and to coordinate your follow-up care. For example, we may disclose your personal information to doctors, nurses, or other health care providers affiliated with Neko Clinic or outside of Neko Clinic who coordinate your care, serve as consultants, or otherwise provide treatment to you. We may also obtain your personal information from other health care providers identified by you and from wearable technologies that you link to your provider account. We may use your personal information to remind you of recommended services, treatment, scheduled appointments, or new products or services that might be of interest to you.
• Payment: We may use and disclose your information to bill and collect payment for products and services we provide to you. For example, we may disclose certain limited health information to charge your credit card, or if you elect to participate through any affiliated clinics, your health insurer.  Your billing information will be linked to your account for future payments unless you opt out.
• Health Care Operations: We may use and disclose your personal information to carry out our own health care operations. For example, we may use your personal information to provide customer services to you, monitor the performance of our providers and technology, or to review and improve the quality and effectiveness of our services.  We may also aggregate or de-identify your data into a pseudonymized format (including your personal information) for statistical analysis, market research, and enhance existing or new products and services, and help us better understand human illness to maximize early detection and treatment.
• To Our Affiliates Who Support Our Services: We may contract with other entities or engage affiliates to perform certain services for us, such as accounting, billing, information technology services, and product development. If these entities need access to your information to perform these services, we will ensure that they agree to reasonable data privacy and security controls to make sure that your information remains confidential and secure.
• People Involved in Your Care, Including Payment: We may share your personal information, with certain people involved in your care or payment for your care as directed by you or otherwise permitted under applicable law. This may include your family members, friends, or caregivers.
• Required by Law: We will disclose your information when we are required to do so by law.
• Law Enforcement: We may disclose your personal information to law enforcement pursuant to a court order, subpoena, warrant, or similar process as required by applicable law. We will attempt to provide you with notice prior to disclosing your information to law enforcement, if we are permitted to do so.
• Judicial and Administrative Proceedings: We may disclose your personal information pursuant to a court or administrative order, subpoena, discovery demand, or other lawful process, in accordance with applicable law. We will attempt to provide you with notice prior to disclosing your information unless such notice has been provided by another party to the dispute.
• Public Health and Safety: We may use or disclose your personal information as permitted or required to address certain public health and safety issues, for example, to report abuse, contagious diseases, product defects, or recalls. We may use and disclose your personal information to prevent a serious health and safety threat to you, the public, or another person. We may also use or disclose your information if we are required to do so by law, if you agree to the disclosure, or if we believe it necessary to prevent serious harm to you or someone else.
• Health Oversight Activities: We may disclose your personal information to a health oversight agency, such as a state Board of Medicine, or state department of health. Examples of these oversight activities include quality reviews, surveys, audits, investigations, credentialing, licensure, government monitoring of the health care system or government programs, and compliance with civil rights laws.
• Research: We may use your personal information to conduct research or disclose it to researchers as authorized by law. For example, we may use or disclose your personal information for a study approved by an authorized review body that establishes processes to ensure the privacy of your information.
• Emergency or Death: We may disclose your personal information to disaster relief groups, or in the event of your death, for example, to coroners, medical examiners, funeral directors, or organ procurement organizations.
• Government, Correctional Facilities, and Military: We may disclose your personal information to a correctional institution if you become an inmate, to the armed forces if you are a member of the military or a veteran, and to federal officials for national security or specialized government functions.
• Use of Technology: We use AI to make our operations more efficient. This may involve, for example, the processing of your personal information by our AI technologies, including Doctor Scribe (the “Neko Scribe”), which is an AI dictation technology used by Neko Clinic to summarize medical records, health and lifestyle questionnaire, scanning data and any other information submitted or generated in connection with the Services, and to convert spoken words into text format for medical documentation purposes, including but not limited to notetaking during patient visits, and drafting reports. The Neko Scribe is used to maximize efficiency and to enhance accuracy in the transcription of verbal information, while allowing our Neko Clinic clinicians to be fully engaged with you. Any summary or report drafted by the Neko Scribe, and any other summary, report, or review conducted through Neko Clinic’s use of emerging technologies, will be reviewed by Neko Clinic clinicians. We may also collect any information you share over the phone (and may record and transcribe such calls; we will provide you with notice of such recording) or information you submit through our chat functions and/or virtual assistants we make available through the Services.
• Product Development and Analytics.  We may use your information for purposes of internal analytics to assess usage of our products, services, and websites, to aggregate data for purposes of training or developing algorithms, or to improve upon our products and service offerings or develop new products or services. This may include use of your personal information by our affiliates and contractors, each of which is held to stringent data security and confidentiality obligations.
• Security and Protection of Rights. To protect your data, the Services and our business operations, our rights and those of our stakeholders and investors, to prevent and detect fraud, unauthorized activities and access, and other misuse of our platform and services, including 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.
• In the Event of a Business Transaction: If we sell or transfer all or a portion of our business or assets (e.g., further to a merger, reorganization, liquidation, or any other business transaction, including negotiations of such transactions), we reserve the right to disclose your information to the buyer and/or new owner.
• Marketing: We would like to notify you of new products and services that we think might be of interest to you. We may send you this information via email or SMS text message if you have provided us with your telephone number and given us consent to send you such SMS text messages. You may opt out of receiving email and SMS texts from us at any time. We will not sell your information or disclose your information to third parties to market their products and services.
• Responses and Feedback. If you participate in surveys, questionnaires, or research conducted by us, such as for market research, user satisfaction, or other similar purposes, we may collect your responses and feedback, and any other information you choose to provide.

• Marketing: We will obtain your consent before disclosing your personal information to any third party for any marketing.
• Sensitive Information: We will obtain your consent before disclosing any mental health or substance abuse treatment records or any sexually transmitted infection information, except where we are required to report to government agencies. State and federal laws provide additional protections for medical records in certain circumstances, and we may ask for your consent before disclosing your medical records where and when required.
• Social Media Information. While using our Services, you may choose to interact with or enable sharing information or content through various platforms or social networking websites. If you choose to share content or interact with our Services using such platforms or social networking websites, we may collect or receive personal information about you that you have provided to that platform and/or social networking website. For example, we may collect information related to your account and profile, public profile picture and postings, and other similar information available on your profile.
• Selling yourhealth information : We are not in the business of selling our customers’ personal information. If we ever do have an opportunity to receive anything of value in exchange for your health information, we would seek consent from you in advance.
• Other: Any other use or disclosure of personal information will be in accordance with applicable state law, including by obtaining your consent, if required.

• Obtain a Paper Copy of this Notice: You have the right to obtain a paper copy of this Notice by contacting our Privacy Office, even if you have previously consented to receiving electronic communications.
• Obtain a Copy of YourPersonalInformation: With a few exceptions, you have the right to get a copy of your personal information that we maintain about you or ask that we send a copy of your personal information to someone else. Please contact our Privacy Office to request your records.
• Request a Change to YourPersonalInformation:  If you feel that your personal information is incorrect or incomplete, you may request that we change or amend it by contacting our Privacy Office and providing a reason supporting your request. If we deny this request, we will tell you the reason for the denial.
• Receive a Report of Past Disclosures of YourHealth Information: You have a right to request a list of our disclosures of your health information (except those disclosures made for Treatment, Payment, and Health Care Operations) by contacting our Privacy Office.
• Specify HowWe Contact You:  If you consent to receive information from us via SMS text, you are consenting to us sending your appointment information and/or transactional messages via SMS, which is not encrypted and could be more susceptible to breach. We may also reach out to you with similar transactional messages via email.  We primarily communicate with you via the patient portal, including for delivery of results, care plans and recommendations. You have the right to direct us to contact you about your care by alternative means (e.g., by phone instead of text). To request confidential communications, please contact our Privacy Office and tell us how you would like to be contacted. We will accommodate all reasonable requests, but if we cannot contact you as you have requested, we may contact you using other contact information we have.
• Receive Notice of aBreach:  You have the right to be notified of a breach that has compromised your personal information, as defined under applicable state law. We will provide this notice as required by law.