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Privacy

Last revised: March 11th, 2025

This is the privacy policy (“Privacy Policy”) that governs how we, Eleos Health, Inc. (“Eleos”, “we”, “our” or “us”), use, collect, disclose, and store Personal Information (defined below) about individuals in connection with the use of: (i) our website www.eleos.health, and any other website that we operate (each, together with its subdomains, content and services, a “Site”); (ii) the Eleos mobile software application (the “App”); and the Eleos platform (“Platform”). The Site, the Platform, and the App are individually and collectively referred to herein as the “Services”.

  1. Introduction. We have implemented this Privacy Policy because your privacy, and the privacy of other users, is important to us. This Privacy Policy explains our online information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Services. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, or other contact information.
  2. Terms of Use and SAAS Agreement. This Privacy Policy forms part of our Terms of Use which is available at https://eleos.health/terms-of-service (“Terms”) and the App’s Software as a Service License Agreement which can be viewed from within the App and which you accepted prior to downloading, installing and/or using the App for the first time (“SaaS Agreement”). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms.
  3. Modification. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective once the revised Privacy Policy is posted on the Site.
  4. What Personal Information We Collect and How We Collect It. 
    1. When you are a Site User browsing and making use of our Site. We collect the Personal Information submitted by you using the website forms including, without limitation, full name, email address, phone number, position, company name and industry, comments, and messages (including, support requests or any other contact us or chat communication/conversation) and any other Personal Information you submit or provide us with.
    2. Account. In order to use certain services that we offer via the Service, you may be required to create an account (“Account”). If you create an Account you will be required to provide us with certain information, such as your name, email address, phone number, your organization name, your clinical degree, your position and title, your clinic’s site, as well as a password that you will use for your Account (“Account Information”). You may also choose to provide additional Personal Information as part of the Account registration process and in connection with your ongoing use of your Account. We may send you a text message to your mobile phone or an e-mail to the e-mail address you submit to confirm your registration. If you choose not to create an Account, you may not be able to access or use certain features of the Service.

Regardless of which method you choose to register your Account, we may send an email to your nominated email address to instruct you on how to confirm your registration.

  1. ‘Contact Us’ Information. If you send us a “Contact Us” request, whether by submitting an online form that we make available or by sending an email to an email address that we display, you may be required to provide us with certain information such as your name and email address.
  2. When You Request a Demo. If you request to “Schedule a Demo” on our Site, we will collect the following information: your full name, your business email, your job title, your company name, and any other information you choose to provide us with.
  3. When You Use The Services. When you log in to our Services we collect the Personal Data, including, log-in details, full name, phone number, email address, IP address, usage pattern of the Services, payment and billing details and any other Personal Information you submit or provide us within the context of the onboarding and provision of the Services. Please refer to Section 7 below for further information about our customer’s patient data.
  4. Recorded Session Data. The App enables the recording of sessions you may participate in with your patients (“Session Recordings”). Your Session Recordings will include anything you may say during the session/s in which the App is used.
  5. Mobile Device Data. We may collect limited information from your mobile device in order to provide the App. Such information may include your mobile device type, mobile device id, and the date and time stamps of App use. In addition, we may deploy tracking technologies within the App to help us gather aggregate statistics, but we will not use Personal Information for such purposes.
  6. Personal Information from Other Sources (e.g., Prospects, Candidates).  If you are active in areas in which Eleos operates we may collect publicly available Personal Information about you, we may also collect Personal Information from referral partners and member organizations. We may use this Personal Information to identify and contact you about our services. Eleos may also obtain Personal Information about you from other sources, including publicly – or commercially –available information, and through third-party data platforms, partners, marketing events, conferences, and service providers.
    1. The Way We Use Personal Information. 
      1. We will use your Personal Information to provide and improve our Services, to send you marketing/advertisement communications that we believe may be of interest to you, to contact you in connection with the Services and certain programs or offerings that you may have registered for, and to identify and authenticate your access to the parts of the Services that you are authorized to access.
      2. We may use your designated email address to: (i) send you updates or news regarding the Services and our products; and/or (ii) respond to a “Contact Us” or administrative request (for example, to change your password).
    2. Use Of Anonymous Information. We may use Anonymous Information (as defined below) or disclose it to third-party service providers in order to improve our Services and enhance your experience with the Services. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners. “Anonymous Information” means information that does not enable identification of an individual user, such as aggregated information about the use of our Services.
  • Customers’ Information
      1. Eleos offers a data management and annotation solution, data automation, and other products and solutions that enable a broad spectrum of healthcare companies and institutions to manage their patient consults and activity on the Services.
      2. Eleos has a contractual relationship with its Customers. In the context of the Services, the Customer can upload and collect (at the Customer’s sole discretion) both Personal Information and Protected Health Information (as defined under HIPAA) (“Customer Information”).
      3. For the avoidance of doubt, Eleos is providing services on behalf of such Customers. Therefore, the Customer is responsible for the security, integrity, and authorized usage of Customer Information in the context of the Services and also for obtaining consent, and permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such Customer Information. Customer Information is not regulated by this privacy policy. This section is in this Privacy Policy only for transparency purposes. If you have any questions about the Customer Information, please contact the Customer directly.
      4. Eleos has a contract with its Customers, and Customers can request for Eleos to execute a business associate agreement (“BAA“) to regulate access to Customer Information. 
    2. Who Do We Share Your Personal Data With?
      1. We do not disclose or share your Personal Information with third parties except to provide you the Services (including, to perform the contract and your instructions) you have requested, or under the following circumstances:
        1. We may share your Personal Information within our corporate group for our internal administrative, billing, and other business purposes as well as to fulfill the purposes mentioned above.
        2. We use third-party vendors, service providers, partners, agents, and advisers to operate our Services, conduct and administer our business, and provide you with Services. Such third parties include billing companies, website infrastructure management, technology solutions, support platforms, cookies, and other similar technologies vendors (including, analytics and business intelligence service providers, CRM tools, marketing tools, hosting/storage, email distribution, and monitoring, authentication, marketing automation, logging and monitoring, sales engagement and automation, data and cyber security services, billing and payment processing services, fraud detection and prevention services, risk management, session recording, consent management platform, and remote access services, and our legal and financial advisors and document management.  
        3. When you attend an event or webinar that is co-sponsored by us and another organization (or our partners), please be aware that we may share your contact details and participation information with such a partner. This sharing of information is aimed at enhancing your event experience and offering you relevant information and opportunities related to the event or webinar. Each co-sponsor may use your information in accordance with their own privacy policies, and we encourage you to review these policies to understand how they process your personal data.
        4. We may disclose information with our lawyers, accountants, auditors, and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests;
        5. In order to enforce any claims we are entitled to (e.g. if you breach the contract).
        6. To the extent necessary, with regulators, courts, public authorities (for example, tax authority), banks, or competent authorities, to comply with applicable laws, regulations, and rules (including, without limitation, federal, state, or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Eleos, our Services, customers, employees, property, and the public. We may use or disclose the information we collect in order to ensure that our users are complying with all applicable aspects of our policies.
        7. If in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we may disclose your Personal Information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors or purchasers (and their advisers), our advisers, with a need to know). In the event that we are acquired by, or merged with, a third-party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Information in connection with the foregoing events.
        8.   In circumstances for which you have given your consent.
      2. If you want to receive the list of the current recipients of your Personal Information, please make your request by contacting us at [email protected].
    3. Your Rights 
      1. The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):
        1. You have a right to access Personal Information held about you. Your right of access may normally be exercised free of charge; however, we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
        2. You have the right to request that we rectify any Personal Information we hold that is inaccurate or misleading;
        3. You have the right to request the erasure/deletion of your Personal Information (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise, or defense of legal claims;
        4. You have the right to object, to or to request restriction, of the processing;
        5. You have the right to data portability. This means that you may have the right to receive your Personal Information in a structured, commonly used and machine-readable format, and that f. you have the right to transmit that data to another controller;
      2. You can exercise your rights by contacting us at [email protected]. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent with written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
      3. Opting Out. You may choose not to receive future promotional, advertising, or other Services-related emails from us by selecting an unsubscribe link at the bottom of each email that we send. Please note that even if you opt-out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative emails (for example, in connection with a password reset request) that are necessary to facilitate your use of the Services.
    4. Choice. At all times, you may choose whether or not to provide or disclose Personal Information. If you choose not to provide mandatory Personal Information, you may still visit parts of the Services but you may be unable to access certain options, programs, offers, and services that involve our interaction with you.
    5. Links to and Interaction with Third Party Products. The Services may enable you to interact with or contain links to your Third-Party Account and other third-party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third-Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.
    6. International Transfers of Personal Information. We do not ourselves host any of the Services – all hosting is done by third-party service providers that we engage. This means that data you provide us or that we collect from you (including any Personal Information, as defined below) – as further described in this Privacy Policy – is hosted with such third-party service providers on servers that they own or control. Regardless of where such third-party service providers are located (and some are located in the US), their servers may be located anywhere in the world (including the US). Your data may even be replicated across multiple servers located in multiple countries. So please be aware that you are consenting to your data being transferred to various third-party service providers around the world (including the US).
    7. Children’s Privacy. The Services are not structured to attract children under the age of 13 years. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 13 years. If we learn that we have collected Personal Information from a child under 13 years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at [email protected].
    8. Security. The security of Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use reasonably acceptable means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Service, you can contact us at [email protected].
    9. Cookies, Analytic Tools and Log files.
      1. Log Files. We may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Services, track users’ movement around the Services, and gather demographic information.
      2. Cookies and Other Tracking Technologies. Our Services may utilize “cookies”, anonymous identifiers and other tracking technologies in order for us to provide our Services and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Services. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
      3. Mixpanel Analytics. The Site may use a tool called “Mixpanel Analytics” to collect information about the use of the Service. Mixpanel Analytics collects information such as how often users visit the Service, what pages they visit when they do so, and what other sites they used prior to coming to the Service. We use the information we get from Mixpanel Analytics to maintain and improve the Service and our products. We do not combine the information collected through the use of Mixpanel Analytics with personally identifiable information. Mixpanel’s ability to use and share information collected by Mixpanel Analytics about your visits to and use of the Service is restricted by the Mixpanel Analytics Terms of Service, available at https://mixpanel.com/legal/terms-of-use, and the Mixpanel Privacy Policy, available at https://mixpanel.com/legal/privacy-policy/. You may learn more about how Mixpanel collects and processes data specifically in connection with Mixpanel Analytics at https://mixpanel.com/legal/terms-of-use/ 
    1. Google Analytics. The Site uses a tool called “Google Analytics” to collect information about the use of the Site Google Analytics collects information such as how often users visit this Site, what pages they visit when they do so, and what other websites they used prior to coming to this Site. We use the information we get from Google Analytics to maintain and improve the Site and our products. We do not combine the information collected through the use of Google Analytics with other personal data we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
    2. We reserve the right to remove or add new tools.
  2. California Privacy Rights. California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]. Please note that we are only required to respond to one request per customer each year.
  3. Our California Do Not Track Notice. We do not track consumers over time and across third-party websites and therefore do not respond to Do Not Track signals. We do not allow third-parties to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.
  4. Contact us. If you have any comments or questions regarding our Privacy Policy or your Personal Information that we may be storing and using, please contact us at [email protected].