Privacy Policy

Last updated November 5, 2025
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This Privacy Notice for Quilt Health Inc. ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:
- Visit our website at www.quilthealth.com or any website of ours that links to this Privacy Notice
- Engage with us in other related ways, including any sales, marketing, or events
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‍Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at Help@QuiltHealth.com.

SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents  below to find the section you are looking for.
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What personal information do we process? 
When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us. 

Do we process any sensitive personal information? 
Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

Do we collect any information from third parties? 
We do not collect any information from third parties.

How do we process your information? 
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? 
We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information. 

How do we keep your information safe? 
We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe. 

What are your rights? 
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? 
The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us
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‍In Short: We collect personal information that you provide to us.

‍We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

‍Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
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•Account Information: Information you provide about yourself to access our Services, including name, email, phone number, address, and password, so that we may communicate with you and provide you with the Services.
•Self - Reported Information: Information you provide about yourself, including your survey answers, demographics, conditions, relationships, interests, disease - specific characteristics, family history, diagnoses, medications, treatments, or any other data you submit while using our Services.
•Patient Information: Information you provide, or authorize the release of, to us, including medical reports, scans, CDs, images, notes, and tests. Patient Information also includes information that you provide about any of these reports, scans, CDs, images, notes, and tests, including annotations, interpretations, labels, dates, and notes.
•Genetic Information: Your Genetic Information includes your DNA information, as well as information relating to your DNA, such as genetic markers that may indicate certain traits. Processing and disclosing genetic data is subject to applicable state and federal requirements, including obtaining specific consents where required.
•Voluntary Information: Information you provide to us voluntarily by completing web forms, participating in polls, or contributing to blogs, postings, and other mediums constitutes Voluntary Information.

‍Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information. social security numbers or other government identifiers.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected
‍In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

‍We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:
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•Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
•Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
•Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Google API
Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Third-Party Sources of Information
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With your permission, we collect some personal information about you from third parties, such as your healthcare providers and other organizations. We do this in order to make it easier for you to access this data and to improve the quality of the Services.

We collect the following information about you from third-party products or services integrated into our Services, such as:
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•Healthcare Providers or Other Entities Authorized by You: As a part of our Services, we collect your Patient Information. We will only obtain personal information about you from the healthcare providers, entities, or persons authorized by you.
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Use and Disclosure of Health Information
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We value the privacy and security of your health information. Because we work with health systems and research partners, certain information we collect or receive about you may qualify as Protected Health Information (“PHI”) under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). This section explains how we use and share PHI and the rights you have with respect to that information.

How We Use PHI
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We may use your PHI and/or personal information for purposes such as:

•Helping to identify, recruit, and match patients with clinical trials, sponsors, or contract research organizations (CROs);
•Supporting health system operations, including workflow improvement, patient outreach, and quality initiatives;
•Performing internal analytics and quality improvement;
•As otherwise permitted or required by law.
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How We Share PHI
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We may disclose PHI and/or personal information:
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•To clinical trial sponsors, CROs, and other research partners for patient recruitment and enrollment, only with your written authorization or as otherwise permitted by HIPAA;
•To our service providers and subcontractors who assist us in providing services, subject to agreements that require them to safeguard PHI;
•As required by law, including to public health authorities, regulators, or in response to valid legal processes.
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We do not sell or use PHI or personal information for marketing purposes without your prior written authorization.

Your Rights Under HIPAA

You have the right to:
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•Request a copy of your PHI that we maintain;Request corrections or amendments to your PHI;
•Receive an accounting of certain disclosures we have made of your PHI;
•Request restrictions on certain uses and disclosures of your PHI (though we may not always be able to agree to them);
•Request confidential communications (for example, contact at a different email or mailing address);
•File a complaint with us or with the U.S. Department of Health and Human Services if you believe your privacy rights have been violated.

Safeguards

We use reasonable administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and security of PHI in our possession.

2. HOW DO WE PROCESS YOUR INFORMATION?
‍In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

‍We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see " WHAT ARE YOUR PRIVACY RIGHTS” below.

• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.

• To post testimonials. We post testimonials on our Services that may contain personal information.

• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.

• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

• Our projects may include studying the clinical characteristics of a condition or disease, analyzing subgroups or cohorts of patients within a condition, and conducting or supporting the development of a drug, device, or diagnostic. We may commercialize this knowledge to improve our understanding of the condition or disease as well as to advance health care to better diagnose, treat, or predict medical conditions. Please refer to the Terms of Use for more information. You have the choice to contribute and participate in our Services by providing us with your informed express consent.

• What am I consenting to? A consent can be given to participate in de-identified research. If you choose to participate in de-identified research, we will de-identify your data prior to sending it to third party researchers. We de-identify your personal information by stripping all your identifying information (e.g., your name, contact information, etc.) and any other data so that you cannot reasonably be directly identified.

• To Provide You with Research Communications. As a part of the Services, you may receive communication involving external parties (such as academic researchers, healthcare institutions, and other research organizations) that would like to conduct new projects which might be relevant to you. In these circumstances, we may notify you via email about opportunities for which you may qualify. Your participation in such research is completely voluntary. You can always manage your email preferences, but basic research communications are necessary for us to continue to provide our Services to you. Where required by law (for example, for certain outreach or any disclosure of your protected health information to a research sponsor), we will first obtain your consent and/or HIPAA authorization. We do not share your PHI with sponsors/CROs for their own use unless you authorize us to do so.

• We may create HIPAA-de-identified and aggregated datasets from PHI to support research, analytics, and to provide and improve the Services. We do not re-identify such data and require our recipients to implement safeguards, prohibit any re-identification, restrict use to specified purposes, and prevent onward disclosure except under equivalent terms. We de-identify using either Safe Harbor or Expert Determination under 45 C.F.R. §164.514.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
‍In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

‍Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

Healthcare Providers or Other Entities Authorized by You. With your authorization, we may share your personal information on your behalf with any healthcare provider, entity, or person for research purposes or as otherwise described to you at the time of sharing.
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The categories of third parties we may share personal information with are as follows:

•Cloud Computing Services
•Data Storage Service Providers
•Sales & Marketing Tools
•User Account Registration & Authentication Services
•Data Analytics Services
•AI Platforms
•Website Hosting Service Providers
•Performance Monitoring Tools
•Testing Tools
•Product Engineering & Design Tools

We also may need to share your personal information in the following situations:

•Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
•Care Navigation. With your direction, we use your information (which may include health-related information you provide) to identify and connect you with providers or centers, facilitate scheduling or intake, provide administrative support relative to coverage, or access therapies to treat your condition. We may share limited information with a provider/center (e.g., your name, contact details, general condition of interest, and location) so the provider/center can contact you. We require providers/centers to use such information only for responding to your request.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
‍In Short: We may use cookies and other tracking technologies to collect and store your information.

‍We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?”

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
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5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of Session Recording and Analytics.

We use third-party analytics services, including LogRocket, to help us understand how users interact with our website and services. LogRocket records certain interactions, such as page views, navigation, and technical information about your device and browser, in order to identify errors, improve performance, and enhance user experience. These recordings may include usage data and technical logs, but we configure LogRocket not to capture sensitive information such as payment details or protected health information. The information collected is used solely for our internal business purposes, is processed in accordance with applicable data protection laws, and is not sold to third parties.

6. HOW LONG DO WE KEEP YOUR INFORMATION?
‍In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

‍We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than two (2) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?
‍In Short: We aim to protect your personal information through a system of organizational and technical security measures.

‍We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process.
However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

Protected Health Information and Personal Information of Minors

We recognize that certain Services may involve the collection, use, and disclosure of PHI and/or personal information relating to individuals under the age of 18. We take the privacy of minors seriously and apply heightened safeguards to such PHI.

Parental or Guardian Consent

•Our Services are not designed for direct use by minors under 18 without the involvement of a parent or legal guardian.
•A parent or legal guardian must provide consent before we collect, use, or disclose any PHI and/or personal information of a minor through the Services. By permitting a minor dependent to access or use the Services, the parent or guardian represents that they consent to the collection, use, and disclosure of that minor’s PHI and/or personal information in accordance with this Privacy Policy and applicable law.
•Where required, we may also seek written or electronic verification of parental/guardian authorization consistent with HIPAA standards.

Scope of Information Collected

•PHI and/or personal information collected from minors may include medical history, treatment information, care coordination data, and other health-related information provided by health care providers, health plans, or directly by parents or guardians.
•We do not use PHI or personal information of minors for marketing or profiling purposes.

Use and Disclosure

•We will use and disclose PHI of minors solely as permitted under HIPAA, applicable state law, and this Privacy Policy.
Disclosures may occur for purposes of treatment, payment, or health care operations, or as otherwise authorized by a parent/guardian or required by law.

Safeguards and Retention

•We implement administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and security of PHI and personal information  relating to minors.
•PHI and/or personal information  of minors will be retained only for as long as necessary to provide the Services or as required by applicable law, after which it will be securely destroyed or de-identified.

Improper Collection

•If we become aware that PHI or personal information of a minor has been collected without appropriate parental or guardian consent, we will promptly take reasonable steps to delete such information, disable related accounts, and, if applicable, notify the parent or guardian.

Please note that in certain states, minors may have the right to consent to specific types of health care services (such as reproductive health, mental health, or substance use treatment) without parental involvement. Where applicable law grants such rights, the minor — and not their parent or guardian — controls the PHI related to that care. We comply with all federal and state laws governing access, use, and disclosure of minors’ PHI, including any state laws that provide additional protections beyond HIPAA. Please note that certain state laws give minors between the ages of 13 and 17 the right to consent to specific types of health care services (such as reproductive health, mental health, or substance use treatment). In those cases, the minor — and not the parent or guardian — may control the PHI relating to that care. We comply with all applicable federal and state laws governing minors’ PHI.

In addition, if our Services collect personal information directly from children under the age of 13 online, we do so in accordance with the Children’s Online Privacy Protection Act (“COPPA”), which requires verifiable parental consent. If we become aware that we have collected PHI or personal information directly from a child under 13 without appropriate parental authorization, we will promptly delete such information and disable associated accounts.

No personal information about a child will be made available to the public or sold. We may share information with our service providers if necessary for them to perform business, professional, or technology services for us, always in accordance with all applicable laws including HIPAA.

9. WHAT ARE YOUR PRIVACY RIGHTS?
‍In Short:  You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

‍Withdrawing your consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with third parties.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
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Cookies and similar technologies

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.If you have questions or comments about your privacy rights, you may email us at Help@QuiltHealth.com.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

‍‍‍11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.
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‍Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?”

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

•Receiving help through our customer support channels;
•Participation in customer surveys or contests; and
•Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:
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•Category A - 3 months
•Category B - 3 months
•Category G - 3 months
•Category H - 3 months
•Category I - 3 months
•Category L - 3 months

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?”

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?”.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

•Category A. Identifiers
•Category B. Personal information as defined in the California Customer Records law
•Category G. Geolocation data
•Category H. Audio, electronic, visual, and similar information
•Category I. Professional or employment-related information

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

•Right to know whether or not we are processing your personal data
•Right to access your personal data
•Right to correct inaccuracies in your personal data
•Right to request the deletion of your personal data
•Right to obtain a copy of the personal data you previously shared with us
•Right to non-discrimination for exercising your rights
•Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

•Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
•Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
•Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
•Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Minnesota)
•Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
•Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at Help@QuiltHealth.com, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at Help@QuiltHealth.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”

12. DO WE MAKE UPDATES TO THIS NOTICE?

‍In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

‍We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at Help@QuiltHealth.com or contact us by post at:160 Federal Street, Suite 2100, Boston, MA 02210

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
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Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request to Help@QuiltHealth.com.

‍15. Notice to Individuals in the European Economic Area and Switzerland
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This section only applies to individuals using or accessing our Service while located in the European Economic Area, the United Kingdom, or Switzerland (collectively, the “Designated Countries”) at the time of data collection.

We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in the Designated Countries.

Our Relationship to You.

We are a data controller with regard to any personal information collected from individuals accessing or using its Services. A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. We use your personal information under certain legal bases permitted under the law, including:

•With your consent
•To satisfy legal obligations
•If we need to, to fulfill a contract with you, or to enter into a contract with you
•In the public interest
•In your vital interests
•Based on our legitimate interests
•For archiving purposes in the public interest, scientific or historical research purposes
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Legal Bases for Processing Your personal information.

We rely on the following Legal Bases under the EU General Data Protection Regulation in processing your personal information.

We will use your personal information for marketing purposes based on legitimate interest or consent, subject to the applicable law.

Marketing

We will only contact you if you are located in the Designated Countries by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law or your consent. If you do not want us to use your personal information in this way, please click the unsubscribe link at the bottom of any of our email messages to you or contact us at Help@QuiltHealth.com. You can object to direct marketing at any time and free of charge. You have certain rights to your personal information, including the right to:

•Withdraw consent
•Access and correct
•Request deletion
•Enjoy data portability
•Restrict processing
•Have us notify relevant third parties of erasure, rectification, and restriction
•Object to processing
•Opt out of automated individual decision - making, including profiling

Each of these rights has conditions and limitations, which are further described in the Policy below.

Individual Rights

We provide you with the rights described below when you use our Services. We may limit your individual rights requests: (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other’s privacy; c) to protect our rights and properties; or (d) where the request is frivolous or unrealistic. If you would like to exercise your rights under applicable law, please contact us at Help@QuiltHealth.com

•You can request access or deletion of your personal information.
•You can correct or update your personal information, object to processing or your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
•If we collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of the processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
•You have the right to complain to your local data protection authority about our collection and use of your personal information.

If you believe we have infringed or violated your privacy rights, please contact us at Help@QuiltHealth.com so that we may resolve your dispute directly.

You also have the right to lodge a complaint with a competent supervisory authority. When we transfer your personal information to a business not located in the EU, we comply with the conditions laid down in Chapter 5 of the General Data Protection Regulation (“GDPR”).

Transfer of Your personal information

We transfer your personal information subject to the appropriate safeguards required under the applicable law. Depending on the circumstances the transfer of your personal information out of the Designated Countries, or an onward transfer of such information, is necessary for the performance of our contract with you, the performance of a contract between us and another party that we entered into for your interest, or for important reasons of public interest. Whenever we share your personal information with another party, we contractually require the recipients to comply with the GDPR and all other applicable data protection laws in processing your personal information and/or use the EU e rely on Standard Contractual Clauses in relation to such transfers.