Raena Health Privacy Policy

Last updated: Jan, 2025

 

Moment Management, Inc. dba Raena Health (“Raena Health” “we,” or “us”) owns and operates the website (the “Website”) located at www.raena.com and may have previously, now or in the future own and/or operate a Raena Health mobile application (collectively, the “Platform”). Your access and use of the Platform, any part thereof, or anything associated therewith, including its content (“Content”), any products or services provided through the Platform or otherwise by Raena Health, and any affiliated website, software or application owned or operated by Raena Health (collectively, including the Platform and the Content, the “Service”) are subject to this Privacy Policy unless specifically stated otherwise. Capitalized terms not otherwise defined in this Privacy Policy have the same meaning as set forth in the Raena Health Terms of Service (“Terms”).

We are committed to respecting the privacy of users of the Service. We created this Privacy Policy (“Privacy Policy”) to tell you how Raena Health collects, uses and discloses information in order to provide you with the Service.

As with our Terms, by creating, registering, or logging into an account through the Service, or otherwise accessing or using the Service, you are automatically accepting and acknowledging the most recent version of this Privacy Policy. If we make any changes to our Privacy Policy, we will post the revised Privacy Policy and update the “Last updated” date of the Privacy Policy.

This Privacy Policy applies to information we collect on our Website, from any devices that interact with our Website or mobile applications, in email, text and other electronic messages between you and our Website and mobile application and when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

This Privacy Policy does not apply to information collected by us offline or through any other means, including on any other website operated by Raena Health or any third-party, including through any application or content (including advertising) that may link to or be accessible from or on the Website or mobile applications.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using the Website and mobile applications, you accept the practices and policies outlined in this Privacy Policy and you hereby consent that we will collect, use, and disclose your information as set forth in this Privacy Policy. If any term in this Privacy Policy is unacceptable to you, your choice is to not use the Website or mobile applications. This Privacy Policy may change from time to time and your continued use of the Website and mobile applications after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Raena customers consent to receive SMS text messages from Raena via our service partner, Active Campaign. End user’s personal info will not be shared or sold to third parties for the purpose of marketing.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Limitations on use by Minors

Our Service is generally intended for use by individuals who are at least eighteen (18) years of age or such older age as may be required by applicable state laws in the jurisdiction in which an individual utilizes the Service. The Service is not designed or intended to attract, and is not directed to, children under thirteen (13) years of age. If we obtain actual knowledge that we have collected personal information through the Platform from a person under thirteen (13) years of age, we will use reasonable efforts to refrain from further using such personal information or maintaining it in retrievable form. Furthermore, if you are under sixteen (16) years of age, then you (or your parent or legal guardian if you are under age 13) may at any time request that we remove content or information about you that is posted on the Platform. Please submit any such request (“Request for Removal of Minor Information”) to either of the following:

• By mail: Raena Health, 201 Lavaca St #615, Austin, TX 78701,  with a subject line of “Removal of Minor Information. If you send by mail, please send by U.S. Certified Mail, Return Receipt Requested to allow for confirmation of mailing, delivery and tracking.
• By email: hi@raena.com, with a subject line of “Removal of Minor Information”

For each Request for Removal of Minor Information, please state “Removal of Minor Information” in the email or letter subject line, and clearly state the following in the body of the request:

• The nature of your request
• The identity of the content or information to be removed
• The location of the content or information on the Platform (e.g. by providing the URL)
• That the request is related to the “Removal of Minor Information”
• Your name, street address, city, state, zip code and email address, and whether you prefer to receive a response to your request by mail or email.

We will not accept any Request for Removal of Minor Information via telephone or facsimile. Raena Health is not responsible for failing to comply with any Request for Removal of Minor Information that is incomplete, incorrectly labeled or incorrectly sent.

Please note that we are not required to erase or otherwise eliminate, or enable erasure or elimination of such content or information in certain circumstances, such as, for example, when an international, federal, state, or local law, rule or regulation requires Management, Inc. to maintain the content or information; when Management, Inc. maintains the content or information on behalf of your Providers (as defined in our Terms) as part of your electronic medical record; when the content or information is stored on or posted to the Site by a third-party other than you (including any content or information posted by you that was stored, republished or reposted by the third-party); when Management, Inc. anonymizes the content or information, so that you cannot be individually identified; when you do not follow the aforementioned instructions for requesting the removal of the content or information; and when you have received compensation or other consideration for providing the content or information.

The foregoing is a description of Raena Health.’s voluntary practices concerning the collection of personal information through the Service from certain minors, and is not intended to be an admission that Raena Health is subject to the Children’s Online Privacy Protection Act, the Federal Trade Commission’s Children’s Online Privacy Protection Rule(s), or any similar international, federal, state, or local laws, rules, or regulations.

Protected Health Information

When you set up an account with Raena Health, you are creating a direct customer relationship with us that enables you to access and/or utilize the various functions of the Platform and the Service as a user. As part of that relationship, you provide information to us, including but not limited to, your name, email address, shipping address, phone number and certain transactional information, that we do not consider to be “protected health information” or “medical information”.

However, in using certain components of the Service, you may also provide certain health or medical information that may be protected under applicable laws. Raena Health is not a “covered entity” under the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, and its related regulations and amendments from time to time (collectively, ” HIPAA“). One or more of the labs, pharmacies or third-party affiliate professional entities we partner with may or may not be a “covered entity” or “business associate” under HIPAA, and Raena Health may in some cases be a “business associate” of a pharmacy or medical provider. It is important to note that HIPAA does not necessarily apply to an entity or person simply because there is health information involved, and HIPAA may not apply to your transactions or communications with Raena Health, the medical groups, the providers, the labs, or the pharmacies. To the extent Raena Health is deemed a “business associate” however, and solely in its role as a business associate, Raena Health, may be subject to certain provisions of HIPAA with respect to “protected health information,” as defined under HIPAA, that you provide to Raena Health, the medical group or the providers (” PHI”). In addition, any medical or health information that you provide that is subject to specific protections under applicable state laws (collectively, with PHI, “Protected Information“), will be used and disclosed only in accordance with such applicable laws. However, any information that does not constitute Protected Information under applicable laws may be used or disclosed in any manner permitted under this Privacy Policy. Protected Information does not include information that has been de-identified in accordance with applicable laws.

The Medical Groups and Providers have adopted a Notice of Privacy Practices that describes how they use and disclose Protected Information. By accessing or using any part of the Service, you are acknowledging receipt of the Notice of Privacy Practices from your Medical Group and Provider(s).

By accessing or using any part of the Service, you are agreeing that even if HIPAA does apply to Raena Health, the medical groups, the providers, the labs or the pharmacies, any information that you submit to Raena Health that is not intended and used solely for the provision of diagnosis and treatment by the medical group and providers, laboratory services by the labs or prescription fulfillment by the pharmacies, is not considered Protected Information, and will only be subject to our Privacy Policy and any applicable state laws that govern the privacy and security of such information. For purposes of clarity, information you provide to Raena Health in order to register and set up an account on the Platform, including name, username, email address, shipping address and phone number, are not considered Protected Information.

YOUR RIGHTS REGARDING PROTECTED HEALTH INFORMATION (PHI)

1. For Treatment:

PHI may be used or disclosed to healthcare providers, pharmacies, or labs to ensure you receive the care and services you need. For example, if you require medical treatment, we may share your information with a provider involved in your care.

2. For Payment:

PHI may be used or disclosed to process payments for healthcare services, including sharing information with your health plan or other payors.

3. For Healthcare Operations:

PHI may be used or disclosed to improve services, conduct training, or evaluate the performance of healthcare professionals.

4. As Required by Law:

PHI may be disclosed if required to do so by federal, state, or local laws, such as responding to court orders or subpoenas.

5. To Prevent Harm:

If we believe an individual poses a serious risk to themselves or others, PHI may be disclosed to the appropriate authorities to prevent harm.

6. For Public Health Activities:

PHI may be disclosed for public health purposes, such as preventing or controlling disease, reporting adverse reactions to medications, or reporting abuse or neglect.

YOUR RIGHTS REGARDING PROTECTED HEALTH INFORMATION (PHI)

As an individual, you have the following rights regarding your PHI:

1. Right to Access:

You have the right to inspect and request a copy of your PHI maintained by Raena and its medical partners.

2. Right to Amend:

If you believe your PHI is incorrect or incomplete, you may request an amendment.

3. Right to Request Restrictions:

You may request that Raena Health and its medical partners restrict the use or disclosure of your PHI for certain purposes.

4. Right to Request Confidential Communications:

You can request that Raena Health and its medical partners communicate with you in a specific manner (e.g., sending mail to an alternative address).

5. Right to an Accounting of Disclosures:

You may request a list of disclosures of your PHI made for purposes other than treatment, payment, or healthcare operations.

6. Right to Complain:

If you believe your privacy rights have been violated, you may file a complaint with Raena, its medical partners, or the U.S. Department of Health and Human Services.

Raena and Its Medical Partners’ Legal Duties Regarding PHI

1. Maintaining Privacy:

Raena and its medical partners are required by law to maintain the privacy of your PHI and to provide this notice outlining their legal duties and privacy practices.

2. Compliance:

Raena and its medical partners are required to comply with the terms of this Privacy Policy and take reasonable steps to protect your PHI.

3. Notification of Changes:

If this Privacy Policy is updated, the revised version will be posted on our website with an updated effective date.

Collection of Information

We collect any information you provide when you use the Service, including, but not limited to:

• Personally identifying information such as your name and contact data such as your e-mail address, phone number, and billing and physical addresses
• Your login and password and other account (” Account”) registration details
• Demographic data (such as your gender, date of birth and zip code)
• Computer, mobile device and/or browser information (e.g., IP address, mobile device ID information, operating system, connection speed, bandwidth, browser type, referring/exist web pages, web page requests, cookie information, hardware attributes, software attributes)
• Third-party website, network, platform, server and/or application information (e.g., Facebook, Twitter, Instagram)
• Usage activity concerning your interactions with the Service and/or third-party websites, networks or applications accessed through the Service (e.g., viewing habits, viewing preferences, viewing history, number of clicks on a page or feature, amount of time spent on a page or feature, identify of third-party websites, networks, etc.)
• Billing, payment and shipping information
• Electronic signature
• Photographic or video images submitted for identification or non-diagnosis or treatment purposes, including photographs of your driver’s license or passport
• Information about third-parties that you refer to us (e.g., name, email, and/or other contact information, relationship)
• Statements or content (e.g., comments, videos, photographs, images) and information about such statements or content, which you submit or publish on or through the Service or which are accessed via your public or linked social media pages (e.g., Facebook, Twitter, Instagram)
• Any other information you provide when you contact or communicate with us


If you use your mobile device to visit, access or use the Service, then additional categories of information that we collect may include

• Your name associated with your mobile device
• Your telephone number associated with your mobile device
• Your geolocation
• Your mobile device ID information
• With your express consent, your contacts and/or contact information (e.g., names, telephone numbers, physical addresses, email addresses, photos) stored on your mobile device
• With your express consent, information about third-party software applications on your mobile device (including, without limitation, general software apps, downloadable software apps, social media apps)

We also collect certain medical information on behalf of the Medical Groups and your Providers, which may include, but is not limited to:

• Health and medical data you submit for diagnosis or treatment purposes, including information in any questionnaires or surveys you complete for these purposes
• Previous doctors or other healthcare providers you visited
• Date of visit
• Images or videos you share for diagnosis or treatment purposes
• Communications with Providers

We may also receive information about you from our partners. For example, as part of our identity verification process, our vendor may send us information they have independently collected, such as your name, age, and estimated location. Our marketing partners may also send us information about you, even if you have not visited or registered on our Website.

Raena Health does not collect or create biometric information about you. To use some of our services, however, we may be required to verify your identity. If you are asked to submit proof of identity (such as a driver’s license or passport) we may share that with our identity verification partner. Raena Health may receive information extracted from your photos, such as information from your driver’s license and a confidence score regarding the validity of your identity document. We use this information to help verify your identity.

How Information is collected

Raena Health might collect personal and non-personal information directly from you when you visit, access or use the Service; when you register with or subscribe to the Service or any products or services available through the Platform; when you “sign in,” “log in,” or the like to the Service; when you allow the Service to access, upload, download, import or export content found on or through, or to otherwise interact with, your computer or mobile device (or any other device you may use to visit, access or use the Service) or online accounts with third-party websites, networks, platforms, servers or applications (e.g., your online social media accounts, your cloud drives and servers, your mobile device service provider); or whenever Raena Health asks you for such information, such as, for example, when you process a payment through the Service, or when you answer an online survey or questionnaire. In addition, if you or a third-party sends Raena Health a comment, message or other communication (such as, by way of example only, email, letter, fax, phone call, or voice message) about you or your activities on or through the Website and/or the mobile application, then Raena Health may collect any personal or non-personal information provided therein or therewith.

In addition to the information we collect directly from you, we may also collect certain information from the medical group and/or providers who provide treatment or other services to you in connection with the use of our Service. This information may include, but is not limited to, diagnoses, treatment plans (including prescription details) and notes, and is accessible and visible through certain components of the Service.

We may also receive information from third-parties that pay for your care or provide you with treatment, laboratory care or prescription medication, which may include, for example, your prescription history and laboratory test results.

Finally, Raena Health might use various tracking, data aggregation and/or data analysis technologies, including, for example, the following:

• Cookies, which are small data files (e.g., text files) stored on the browser or device you use to view a website or message. They may help store user preferences and activity and may allow a website to recognize a particular browser or device. There are several types of cookies, including, for example, browser cookies, session cookies, and persistent cookies. Cookies may record information you access on one page of a website to simplify subsequent interaction with that website, or to help streamline your transactions on related pages of that website. Most major browsers are set up so that they will initially accept cookies, but you might be able to adjust your browser’s or device’s preferences to issue you an alert when a cookie is downloaded, or to block, reject, disable, delete or manage the use of some or all cookies on your browser or device. Cookies can be set by the website owner (i.e., us), or they can be set by third-parties (e.g., Facebook, Google, etc.) Cookies are used to help us speed up your future activities or to improve your experience by remembering the information that you have already provided to us. Third-party cookies may also be used to enable analytics (e.g. Google Analytics) or advertising functionality (e.g., ad re-targeting on third-party websites) that enables more customized services and advertising by tracking your interaction with our Service and collecting information about how you use the Service.
• Flash cookies, which are cookies written using Adobe Flash, and which may be permanently stored on your device. Like regular cookies, Flash cookies may help store user preferences and activity, and may allow a website to recognize a particular browser or device. Flash cookies are not managed by the same browser settings that are used for regular cookies.
• Web beacons, which are pieces of code embedded in a website or email to monitor your activity on the website or your opening of the email, and which can pass along information such as the IP address of the computer or device you use to view the website or open the email, the URL page on which the web beacon is located, the type of browser that was used to access the website, and previously set cookie values. Web beacons are sometimes used to collect advertising data, such as counting page views, promotion views or advertising responses. Disabling your computer’s, device’s or browser’s cookies may prevent some web beacons from tracking or recording certain information about your activities.
• Scripts, which are pieces of code embedded in a website to define how the website behaves in response to certain key or click requests sent by the user. Scripts are sometimes used to collect information about the user’s interactions with the website, such as the links the user clicks on. Scripts are often times temporarily downloaded to the user’s computer or device from the website server, active only while the user is connected to the Website and/or the mobile application, and deactivated or deleted when the user disconnects from the Website.
• Analytic tools and services, which are sometimes offered by third-parties, and which track, measure and/or generate information about a website’s or program’s traffic, sales, audience and similar information, and which may be used for various reasons, such as, for example, statistical research, marketing research, and content ratings research, and conversion tracking. Examples of the analytic tools and services which we might use include Google Analytics. Raena Health may also use other third-party analytic tools and services.

Please be advised that if you choose to block, reject, disable, delete or change the management settings for any or all of the aforementioned technologies and/or other tracking, data aggregation and data analysis technologies, then certain areas of the Platform might not function properly.

By visiting, accessing or using the Service, you acknowledge and agree in each instance that you are giving Raena Health permission to monitor or otherwise track your activities on the Service, and that Raena Health may use the aforementioned technologies and/or other tracking, data aggregation and data analysis technologies. Notwithstanding the foregoing, Raena Health does not permit third-parties or third-party cookies to access to any communications you have with the Providers, or medical information that you submit to the Providers for diagnosis and treatment purposes.

Use of Information

In connection with providing the Service, we and our third-party affiliates and service providers may use your information, subject to the limitations addressed in the Protected Health Information Section above, for a number of purposes, including, but not limited to:

• Verifying your identity;
• Confirming your location;
• Administering your account;
• Fulfilling your requests;
• Processing your payments;
• Facilitating your movement through the Service;
• Facilitating your use of the Service and/or products or services offered through the Service;
• Communicating with you by letter, email, text, telephone or other forms of communication, including on behalf of your provider(s) to facilitate telehealth Services;
• Providing you with information about Raena Health, the labs, the pharmacies, the medical groups, the providers and/or their businesses, products and services by letter, email, text, telephone or other forms of communication;
• Providing you with customer support;
• Providing you with information about third-party businesses, products and services by letter, email, text, telephone or other forms of communication;
• Developing, testing or improving the Service and content, features and/or products or services offered via the Service;
• Identifying or creating new products, services, marketing and/or promotions;
• Promoting and marketing Raena Health, the Service, and the products and/or services offered via the Service;
• Improving user experiences with the Service;
• Analyzing traffic to and through Service;
• Analyzing user behavior and activity on or through the Service;
• Conducting research and measurement activities for purposes of product and service research and development, advertising claim substantiation, market research, and other activities related to Raena Health, the Service or products and services offered via the Service;
• Monitoring the activities of you and others on or through the Service;
• Placing and tracking orders for products or services on your behalf;
• Protecting or enforcing our rights and properties;
• Protecting or enforcing the rights and properties of others (which may include you);
• When required by applicable law, court order or other governmental authority (including, without limitation and by way of example only, in response to a subpoena or other legal process); or
• Raena Health believes in good faith that such use is otherwise necessary or advisable (including, without limitation and by way of example only, to investigate, prevent, or take legal action against someone who may be causing injury to, interfering with, or threatening the rights, obligations or properties of Raena Health, a user of the Service, which may include you, or anyone else who may be harmed by such activities or to further Raena Health’s legitimate business interests).

We may de-identify your information and use, create and sell such de-identified information for any business or other purpose not prohibited by applicable law.

Disclosure of Information

Subject to the limitations described in the Protected Health Information section above, we may disclose your information to third-parties in connection with the provision of our Service or as otherwise permitted or required by law. For example, we may disclose your information to:

• Other entities within the Raena Health corporate family;
• Our third-party and service providers (collectively “vendors”) that provide services to enable us to provide the Service, such as the hosting of the Service, data analysis, IT services and infrastructure, customer service, e-mail delivery, and other similar services;
• Our vendors that provide services to enable us to run our business and administrative operations, such as legal and financial advisory services, auditing services, analytics and similar services;
• Our vendors that provide services to enable us to promote and advertise the Service and the products and/or services offered via the Service, such as ad platforms or ad-retargeting services, as well as comply with contact removal requests or requirements, such as mailing list removal services, do not call registries, and similar services;
• The labs, pharmacies, medical group or its providers to enable them to provide services to you via the Service and to collect payment on their behalf;
• Vendors as we believe necessary or appropriate to comply with applicable laws; and
• To a third-party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, liquidation or other disposition of all or any portion of our business, assets or stock with such third-party.

We may de-identify your information and disclose such de-identified information for any purpose not prohibited by applicable law.

Data Retention

We may retain your information for as long as necessary to comply with legal obligations, resolve disputes and/or enforce agreements; and/or as long as needed to provide you with the products and/or services of the Service offered by Raena Health. We may dispose of or delete any such information at any time, except as set forth in any other agreement or document executed by Raena Health or as required by law.

Similarly, the third-party affiliated professional entities, medical groups and providers may retain your information for as long as they believe necessary; as long as necessary to comply with their respective legal obligations, resolve disputes and/or enforce its agreements; and/or as long as needed to provide you with the products and/or services of the medical groups and providers. The medical groups and providers may dispose of or delete any such information at any time, except as set forth in any other agreement or document executed by the medical groups or providers or as required by law.

Jurisdictional Issues

The Service may only be used within certain states within the United States as described in our Terms. Accordingly, this Privacy Policy, and our collection, use, and disclosure of your information, is governed by U.S. law.

Third-Parties

This Privacy Policy does not address or apply to, and we are not responsible for, the privacy, information or other practices of any third-parties, including, without limitation, the medical group or its providers, the manufacturer of your mobile device, and any other third-party mobile application or website to which our Service may contain a link. These third-parties may at times gather information from or about you. We do not control and are not responsible for the privacy practices of these third-parties. We encourage you to review the medical group’s Notice of Privacy Practices and the privacy policies of each website and application you visit and use.

Summary of Information Practices

The following table summarizes our personal information collection, use, and sharing practices in the preceding 12 months since we last updated this Policy. As reflected in this table, we may share your personal information with a variety of outside entities. In all cases, information covered by this Privacy Policy may be shared with Raena Health.

Category of Personal Information Collected	Examples	Categories of Sources	Commercial/Business Purpose	Categories of Third-Parties with Whom We Share Personal Information
Identifiers	Full name, email address, phone number, account login and password, purchase information, billing address, physical address	You, our and third-party cookies and other tracking technologies on our website, and service providers.	Facilitating use of Services and/or products or services, processing payments, marketing, customer, or analytic services, protecting against malicious, deceptive, fraudulent or illegal activity, and enabling or effecting, directly or indirectly, a commercial transaction	Service providers, Medical Groups, Providers, Pharmacies, third-parties that assume control over all or part of the business in connection with a merger, acquisition, bankruptcy, or similar event, affiliates, professional advisors, law enforcement authorities, and those involved in legal proceedings, with consent
Unique identifiers or personal identifiers	IP address, online identifiers, mobile device ID, dates of medical visit	You, your mobile device, and our and third-party cookies and other tracking technologies on our website	Processing or fulfilling orders and transactions, debugging to identify and repair errors that impair existing intended functionality, providing customer or analytic services, and enabling or effecting, directly or indirectly, a commercial transaction	Service providers, Medical Groups, Providers, Pharmacies, data analytic providers, payment processors, affiliates, professional advisors, law enforcement authorities, and those involved in legal proceedings, with consent
Internet and other network activity	Browsing activity	Your mobile devices and computers used to access our Site	Marketing, customer, or analytic services and enabling or effecting, directly or indirectly, a commercial transaction	Service providers, data analytic providers, affiliates
Demographic information	Gender, date of birth, zip code	You and our vendors	Marketing, customer, or analytic services, processing or fulfilling orders, transactions and identity verification	Service providers, data analytic providers, affiliates
Audio, electronic, visual, thermal, olfactory, or similar information	Electronic signature, photographic or video images	You	Identification verification or non-diagnosis or treatment purposes, on behalf of Medical Groups/Providers for diagnosis or treatment purposes	Medical Groups and Providers
Commercial Activity	Information about goods or services purchased, obtained, or considered	Your mobile device	Processing or fulfilling orders and transactions, marketing, customer or analytic services	Service providers, data analytic providers, affiliates
Health and Medical Information	Medical history and other information, symptoms, prescription history, insurance policy, insurance eligibility and coverage, laboratory test results, previous doctors visited	You or Medical Group and/or Providers	Processing or fulfilling orders and transactions	Medical Groups and Providers
Financial Information (Information under California Civil Code 1798.80)	Payment information	You	Processing or fulfilling orders and transactions	Payment processors, buyers on Service, sellers on Service
Geolocation information	Geolocation	Your mobile devices and computers used to access our Site, and our vendors	Confirming location and verifying identity	Medical Groups and Providers
Professional or Employment-related Information	Professional or Employment-related Information	Applicants or non-applicant email addresses or signature blocks	Process and evaluate applications for positions with Raena	Service providers such as HR vendors

California Residents

If you are a California resident, you have the right to know what personal information we collect, use, disclose or sell about you under the CCPA. Additionally, you have the right to access and delete your personal information.

To exercise these privacy rights and choices, please follow the instructions below:

How to request access to your personal information: You may request access to your personal information twice in a 12-month period. To do so, please email us at hi@raena.com with the subject heading “California Privacy Rights,” or call 949-464-4520. In response, we will produce a report detailing the personal information we have collected, disclosed, and/or sold about you. This report will be delivered by mail or electronically at your request. Note, we may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way. Please be aware that not all information sharing is covered by the California Privacy Rights requirements and only information on covered sharing will be included in our response.

How to request deletion of your personal information: You may request that we delete the personal information it has collected and/or maintained about you. To do so, please email us at hi@raena.com or call 949-464-4520. Note, we may need to retain certain personal information as permitted by law, such as to complete the transaction for which the personal information was collected, maintain an electronic medical record for a medical group or provider, provide a requested good or service, detect security incidents, protect against malicious, deceptive, fraudulent or illegal activities, comply with legal obligations or to enable solely internal uses that are reasonably aligned with your expectations or lawful within the context in which you provided the information.

We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Verification:

Please note, we will take steps to verify your identity before fulfilling any of the above requests. We will verify your identity by matching two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification (e.g., browser or device ID).

Authorized Agents:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your or your minor child’s personal information. In order to designate an authorized agent to make a request on your behalf, you must provide written proof that you have consented to this designation unless the agent has power of attorney pursuant to California Probate Code sections 4000-4465. You must also verify your identity directly with us by providing a copy of your government issued identification.

Response Timing and Format:

If you are a Raena Health customer with an online account, we will deliver our written response to that account online or via email. If you are not a customer or do not have an online account, we will deliver our written response by mail or electronically, at your preference. The response will also explain the reasons we cannot comply with a request, if applicable. Please note, that if you are submitting a request regarding information you provided to a medical group, a providers, or a pharmacy, your request should be directed to that entity.

Anti-Discrimination Right:

We will not discriminate against you for exercising any of your CCPA rights. But note that some of the functionality and features available to you may change or no longer be available to you upon deletion of your personal information or opt-out of sale of your personal information.

We do not sell your personal information for money, but we use cookies and similar technologies. Please see the section on cookies in “How Information is Collected” regarding our cookie usage. Additionally, some of our vendors may use your data in a way that could be construed as a sale of data under the CCPA, for example by using machine learning on identity documents to improve an identity verification platform as a whole. To opt out of the sale of data, contact us at hi@raena.com or call 949-464-4520.

Miscellaneous

We strive to use reasonable physical, technical and administrative measures to protect information under our control. However, you must keep your Account password secure and your Account confidential, and you are responsible for any and all use of your Account. If you have reason to believe that the security of your Account has been compromised, please notify us immediately in accordance with the “Contacting Us” section below.

When using the Service, you may choose not to provide us with certain information, but this may limit the features you are able to use or may prevent you from using the Service altogether. You may also choose to opt out of receiving certain communications (e.g., newsletters, promotions) by emailing us your preference. Please note that even if you opt out, we may still send you Service-related communications. We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how we do so in this Privacy Policy. Raena Health may supplement, amend, or otherwise modify this Privacy Policy at any time. Such supplements, amendments and other modifications will be posted on this or a similar page of the Service, and shall be deemed effective as of the “Last Updated” date; provided, however, that Raena Health will notify you and/or require you to accept the updated Privacy Policy if the supplemented, amended or otherwise modified Privacy Policy implements material changes from Raena Health’s then-current Privacy Policy. It is your responsibility to carefully review this Privacy Policy each time you visit, access or use the Service.

Contacting Us

If you have any questions about this Privacy Policy, please contact us by email at hi@raena.com or by regular mail at: Raena Health, 201 Lavaca St #615, Austin, TX 78701.