Campus MedShield Privacy Policy

Introduction

Campus MedShield Management Company, LLC (“Campus MedShield,” or “we,” “our,” or “us”) respects your privacy. We are committed to protecting it through our compliance with this Privacy Policy.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the website www.campusmedshield.com (our “Site”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy applies to information we collect:

• on our Site;
• in email, text, and other electronic messages between you and our Site
• our advertising and applications on third party websites and services, if those applications or advertising include links to this Privacy Policy

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by Campus MedShield or any third party;
• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site, or any third party website or application that may redirect you to our Site

Note, Campus MedShield is not a medical group and is not a “covered entity” as defined by the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, and its implementing regulations (collectively, “HIPAA”). Any telemedicine consults obtained through our Site are provided by independent medical practitioners, including EJWK Medical PC (“Medical Group”), an independent medical group with a network of United States based health care providers (each, a “Provider”). Medical Group (or your own medical provider if you do not use a Provider) may be responsible for providing you with a Notice of Privacy Practices describing its collection and use of your health information, not Campus MedShield. If you do not agree to be bound by those terms, you are not authorized to access or use our Site, and you must promptly exit our Site.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Site. By accessing or using our Site, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of our Site after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Children Under the Age of 18

Our Site is not intended for children under 18 years of age. No one under age 18 may provide any information to or through the Site. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Site or on or through any of their features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18 that was provided without verified parental consent, please contact us at investors@campusmedshield.com.

Information We Collect About You and How We Collect It

Generally

We collect several types of information from and about users of our Site, specifically information:

• by which you may be personally identified, such as name, postal address, billing address, shipping address, e-mail address, mobile telephone numbers, driver’s license number (or other government identification number), date of birth, financial account numbers, bank account numbers, credit or debit card numbers (bank, credit, debit, and other financial account numbers are collected for payment purposes only), your medical history, [biometrics (including fingerprints)], and health information (“Personal Data”);
• that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Site, error information, clickstream data, and other communication data and the resources that you access and use on the Site; or
• about your Internet connection, the equipment you use to access our Site and usage details.

We collect this information:

• directly from you when you provide it to us;
• automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies; and
• From third parties, for example, from the Providers.

Information You Provide to Us

The information we collect on or through our Site is:

• information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, using our physician consultation services, purchasing products, or requesting further services. We may also ask you for information when you report a problem with our Site;
• information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, using our physician consultation services, purchasing products, or requesting further services. We may also ask you for information when you report a problem with our Site;
• records and copies of your correspondence (including email addresses), if you contact us or a Provider.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:

• details of your visits to our Site, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Site, error information, clickstream data, and other communication data and the resources that you access and use on the Site; and
• information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, and browser type.

The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service by enabling us to:

• estimate our audience size and usage patterns;
• store information about your preferences, allowing us to customize our Site according to your individual interests;
• recognize you when you return to our Site.

Cookies and Other Similar Technologies Used on Our Sites

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies)
• Flash Cookies
• Web Beacons
• Third Party Cookies
• Google Analytics
• Pixel tags (also called beacons or pixels).

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Data:

• to present our Site and its contents to you;
• to provide you with information, products, or services that you request from us;
• to process, fulfill, and administer transactions and orders for products and services ordered by you;
• to provide you with notices about your Campus MedShield Account;
• to contact you in response to a request;
• to administer quizzes, surveys, sweepstakes, promotions, and contests;
• to fulfill any other purpose for which you provide it;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to notify you about changes to our Site or any products or services we offer or provide though them;
• for internal testing, research, analysis, and product development, including to develop and improve the Site or our services, and monitor and analyze the effectiveness of content on the Sites;
• in any other way we may describe when you provide the information; and
• for any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications or by visiting your Account Preferences page.

Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this Privacy Policy:

• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Campus MedShield about our Site users are among the assets transferred;
• to fulfill the purpose for which you provide it. For example, we may disclose your personal information to a Provider;
• for any other purpose disclosed by us when you provide the information;
• with your consent.

We may also disclose your Personal Data:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; and
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Campus MedShield, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. These third parties may aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

• Tracking Technologies and Advertising. You can set your browser or operating to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Site may then be inaccessible or not function properly. To learn more about your opt- out rights from third parties that directed you to our Site, please visit and review the applicable third party’s website and privacy policy.
• Promotional Offers from Campus MedShield. If you do not wish to have your email address used by Campus MedShield to promote our own products and services, you can opt-out at any time [by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us]. This opt out does not apply to information provided to Campus MedShield as a result of a product purchase, or your use of our services.
• Targeted Advertising. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You also can opt-out of receiving targeted ads from members of the NAI on its website.

Applicability of HIPAA

As described above, you understand that Campus MedShield is not a covered entity as defined by HIPAA. In some cases, Campus MedShield may be considered a business associate of a covered entity. If Campus MedShield is deemed a business associate, we will be subject to additional protections of your protected health information (“PHI”) as defined under HIPAA. If we are operating as a business associate to a covered entity PHI will be used and disclosed only in accordance with such applicable laws, regulations, and contractual protections.

Your Choices

We respect your right to make choices about the ways we collect, use, and disclose the information you provide on or through our Site. We strive to provide choices to you at a meaningful time and in a meaningful place. If you would like to opt out of having participating entities collect your online behavior for advertising purposes when you are browsing our Site, click here for a “Site Opt Out.” You will be directed to an industry-developed website that allows you to choose whether each listed entity may collect and use data for interest-based advertising purposes. It may be that some of the third parties that collect interest-based information on our Site do not participate in the Site Opt Out, in which case the best way to avoid third-party tracking of your online behaviors may be through your browser settings and deletion of cookies.

The Site Opt Out described above works only on websites. To opt out of having participating entities track your behaviors for advertising purposes when you are using a mobile app, download and use the Digital Advertising Alliance’s “App Choices” app. As with the Site Opt Out, the “Mobile App Opt Out” prevents tracking only by participating entities.

Please note that the Site Opt Out and Mobile App Opt Out are device-specific and the Site Opt Out is browser-specific. If you wish to opt-out from having interest-based information collected by participating entities across all devices and browsers, you need to take the steps outlined above from each device and browser.

Previously Expressed Preferences. You may change previously expressed preferences regarding how we use information you provide on or through our Site. For example, if you have provided your contact information and receive periodic emails from us, you may decide to stop receiving those emails by clicking the “unsubscribe” link in an email’s footer. You may be able to change other preferences through an account you create on our Site. Otherwise, please contact us using the information provided below.

Your Rights Regarding Your Information and Accessing and Correcting Your Information

You can review and change your Personal Data by logging into our Site and visiting your profile section of our Site. We may ask you to verify your identity before we display or allow any changes to your Personal Data. You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible or to delete your profile. In most cases, we will provide access and correct or delete any inaccurate information you discover. In some cases, however, we may limit or deny your request if the law permits or requires us to do so or if we are unable to verify your identity. If you seek deletion of information that you provided when you were a minor, please contact us using the information provided below.

Do Not Track Signals

Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals, but we currently do not use automated data collection technologies to collect information about your online activities over time and across third party websites or other online services (behavioral tracking).

Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We use encryption technology for information sent and received by us. The safety and security of your information also depends on you. Where you have chosen a password for the use of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Site. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or in your operating system.

California’s Shine the Light Law

California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Sites and/or our services that are California residents and who provide Personal Information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared your Personal Information with for the immediately prior calendar year (e.g., requests made in 2022 will receive information regarding such activities in 2021). You may request this information once per calendar year. To make such a request, please Contact Us using the information below.

Changes to Our Privacy Policy

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Site’s home page. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address specified in your profile and/or through a notice on the Site’s home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and reviewing this Privacy Policy to check for any changes.

Contact Information

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the contact information displayed on our Site.

How to Contact Us:

Send an email to support@campusmedshield.com.