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PRIVACY POLICY


EFFECTIVE DATE: FEBRUARY 2017


INTRODUCTION

Cedar is a software platform available through our website or mobile app,
designed to help patients make timely payments to their health care providers.
If your health care provider has a contract with Cedar, you will be able to
receive reminders about payments and pay through a secure Internet portal
maintained by Cedar, which for some patients may include participating in a
recurring payment plan.
This Privacy Policy tells you how Cedar handles your personal information,
including health information, collected from or about you by Cedar in order to
provide you with payment services that Cedar provides on behalf of your
healthcare provider. This Privacy Policy applies both to the Cedar website and
the Cedar mobile application.
This Privacy Policy is distinct from your health care provider’s HIPAA Notice of
Privacy Practices, which describes how your health care provider uses and
discloses your individually identifiable health information (“Information”). As
your health care provider’s business associate, Cedar has agreed that its
collection, use, and disclosure of your Information on behalf of your health
care provider will be done in accordance with your health care provider’s HIPAA
Notice of Privacy Practices.
Reading this Privacy Policy and your health care provider’s HIPAA Notice of
Privacy Practices (which is provided to you by your health care provider) will
help you understand how any Information we collect from you through the Platform
or directly from your health care provider is used and/or disclosed. If there is
any inconsistency between this Privacy Policy and your health care provider’s
HIPAA Notice of Privacy Practices, your health care provider’s HIPAA Notice of
Privacy Practices shall govern.
In general, a reference to “Cedar,”“we,”“our,” or “us” in this policy means
CarePortal, Inc., the company that operates the Cedar Platform, a payment
portal. A reference to the “Platform” in this policy means the software platform
that allows you to elect to receive reminders and submit payments to your health
care provider, and it includes both the Cedar website and the Cedar mobile app.
When you use the Platform, you are accessing Cedar’s back-end system.
Information will be stored on this system and not on your mobile device.
By using the Platform, you agree to accept the practices described in this
Privacy Policy. If you do not agree to all the terms of this Privacy Policy,
please do not use the Platform.


INFORMATION WE COLLECT AND RECEIVE


1. HOW WE COLLECT INFORMATION

Your health care provider will provide us with information so that we can
provide our services to you on behalf of your health care provider, including
informing you of the payments you need to make. This information may include a
description of services you have received from your health care provider and the
associated dates and charges, insurance information, and contact information as
further described below.
We also receive information you provide when you use the Platform, create an
account, submit a payment, or contact us with a request or question. In
addition, we collect some other information from your computer or mobile device
automatically, including various technical information.


2. CATEGORIES OF INFORMATION

The information that we collect includes the following categories:
 * Account information. When you create an account, you provide us with
   information such as a username and password.
 * Contact information. You and your health care provider may provide us with
   your telephone number, including mobile device number, email address, and/or
   mailing address.
 * Health services information. Your health care provider may provide us with
   information about the services you have received, your insurance information
   and the payments due.
 * Billing and other information. We or our third party payment processors may
   collect and store billing information such as billing address, credit card or
   debit card number, bank account information or other payment account
   information (e.g., Paypal or similar payment services as applicable) in
   accordance with the Payment Card Industry Data Security Standard (PCI DSS).
 * Automatically Collected Data (Log data). Our servers automatically record
   some information about your interactions with the Platform, such as number of
   log-ins, time and date of payments and visits to the Platform, the type of
   device you are using, your operating system, your Internet Protocol address,
   sites or apps visited before and after coming to our Platform, and data from
   online cookies and similar technologies, which may be collected over time and
   across different websites and apps.
 * Other Third Party Information. We may supplement or enhance the data we have
   about you with information from various third party information sources.
 * Location Information. With your consent obtained through your mobile device
   platform, we may collect geolocation information based on your mobile device
   location.


HOW WE USE YOUR INFORMATION

We use, on behalf of your healthcare provider, your information in accordance
with applicable laws to:
 * Provide the Platform. We use your information to facilitate payments from you
   to your healthcare provider. We use billing information to allow you to make
   these payments.
 * To contact you. We use your contact information to remind you about payments
   that need to be made and to communicate with you about your account. Please
   note that we may communicate with you by email, telephone call, text message
   or mail. We also may contact you by telephone or text message at your
   wireless device number using autodialer technology.
 * To respond to your requests. If you contact us with a concern or question, we
   will use your information to respond to you.
 * Investigating and preventing fraud and abuse. We may use the information we
   collect to detect, prevent, and respond to fraud, intellectual property
   infringement, violations of law, other misuses of the Platform, and to
   protect the rights of us, or customers and our users.

Further, we will use your Information in accordance with our agreements with
your healthcare provider.
When authorized by your healthcare provider, we may de-identify your information
in accordance with applicable laws and use that de-identified data for any
purpose, including:
 * To understand and improve the Platform. We use log data to understand how
   users are using the Platform and to improve it.
 * To perform analytics. We use all of the information we collect to analyze how
   different types of consumers use and interact with our services, including
   user trends.


YOUR PRIVACY CHOICES

You may update billing information, including settings for recurring payments,
by logging in to your account. If your contact information changes, please both
inform your health care provider and update the information in your account. If
you no longer wish to receive communications from Cedar, please inform your
health care provider. You also have the rights set forth in your healthcare
provider’s notice of privacy practices.


SHARING YOUR INFORMATION

We may disclose the information that we collect: (a) as and when authorized by
your health care provider, for purposes of your health care provider’s
treatment, payment health care operations and other purposes permitted by
applicable law; (b) to our service providers and affiliates who work on our
behalf and have agreed to adhere to the rules set forth in this Privacy Policy
and contracts required by applicable law and our agreements with your healthcare
provider; (c) to law enforcement, governmental entities or other third parties
pursuant to appropriate legal process; or (e) otherwise with your consent in
accordance with our agreement with your healthcare provider and applicable law.
We may buy or our business or a portion of our business or assets may be bought
by other businesses or entities. In such event, we may transfer or assign the
information we have collected as part of such merger, acquisition, sale change
of control or other disposition of assets. In such transactions, your
information may be included in the transferred business assets. Also, in the
unlikely event of our bankruptcy, insolvency, reorganization, receivership or
assignment for the benefit of creditors, or the application of laws or equitable
principles affecting creditors’ rights generally, we may not be able to control
how your information is treated, transferred, or used and your personal
information may be included in the transferred assets.
We may share aggregate or de-identified information, such as statistical
information, with third parties.


SECURITY

We maintain certain administrative, technical, and physical safeguards designed
to protect the privacy and security of the information we collect through the
Platform and directly from your health care provider. However, no information
system can be 100% secure, so we cannot guarantee the absolute security of your
information. Moreover, we are not responsible for the security of information
you transmit to the Platform over networks that we do not control, including the
Internet and wireless networks.
Of course, we appreciate your help in safeguarding the integrity of your own
privacy. Please keep your username and password confidential and safe from
discovery by others, and close your browser or mobile app after you are done.
Just as important, we encourage you to let us know immediately if you suspect
that the information you share with us is being used by an unauthorized person
or in an unauthorized manner. To contact us, see the contact information below.


CHILDREN’S INFORMATION

Our Platform is not directed to children, and we do not knowingly collect online
information from children under the age of 13 or minors. We do, however, collect
the personal information that the health care provider, a parent, or legal
guardian may submit to us about a minor.


DO NOT TRACK

Some browsers may transmit “do-not-track” signals to websites with which the
browser communicates. The Cedar website does not currently respond to these
“do-not-track”signals.


CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy from time to time by posting
a new Privacy Policy to this page. You are advised to check this Privacy Policy
regularly for any changes. By continuing to use the Platform after such changes
have been made, you agree to those changes. If we make any material changes to
this Privacy Policy, we will either notify you or place a prominent notice on
our website and mobile app.


CONTACTING US

Please feel free to contact us if you have any questions about this Privacy
Policy. You may contact us at: contact@cedar.com