SYRA HEALTH PRIVACY NOTICE

EFFECTIVE DATE: January 2024

INTRODUCTION

The Syra Health Privacy Policy explains how Syra Health and its business partners (collectively “we,” “us,” or “our”) use and disclose personal information in connection with your use of our website or mobile applications, such as CarePlus, Syrenity, and SyraBot (collectively our “Services”). This Privacy Policy describes what information we collect and how we will gather, share, use, and protect that information. “You,” “your,” “user,” and similar terms refer to you, the individual interacting with Syra Health, any person on whose behalf you are interacting with Syra Health, and any person or entity that has rights through you.

We appreciate that you trust us with your information and we intend to honor that trust.

YOUR PRIVACY IS IMPORTANT TO US. PLEASE READ THIS PRIVACY NOTICE CAREFULLY. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, THEN PLEASE DO NOT USE THE SERVICES.

This Privacy Policy is incorporated into and made a part of the Terms of Use. If you have not done so already, please also review the Syra Health Terms of Use. By using our Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy, and agree to the Syra Health Terms of Use, which are incorporated by reference.

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies only to information collected through interactions when Syra Health provides you with products and or Services or through other interactions with Syra Health and its clients. This Privacy Policy does not apply to information that is collected by any third-party websites or services that you may access through the Services.

INFORMATION WE COLLECT

There are several ways we may obtain information about you, including through (A) information you provide to us directly; (B) information we receive from third parties; or (C) information that we automatically collect. Some of the information may directly or indirectly identify you personally as an individual. When information identifies or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, it is referred to as “Personal Information.” Personal Information includes the following categories:

Personal Identifiers, such as contact information like name, address, email, user ID, and other unique identifiers that may identify your information even if not by name.

Device Information, including information about your computer, phone, tablet, or other devices used to access our Services. This may include things like automatic logs of your device ID and type, operating system, browser information, session start and end time, usage information, and device settings and characteristics.

Internet/Electronic Information, including IP address, web browsing history related to our Services, usage information, and interaction information when you interact with our Services or our website (such as browser type, internet service provider, and log information).

We may also work with various types of data that are de-identified or aggregated and not reasonably capable of being associated with, or being reasonably linked, either directly or indirectly, with you or your household. This data is not Personal Information.

Sensitive Personal Information

Due to the nature of our Services, we may be provided, process, and share a special class of Personal Information referred to as Sensitive Personal Information in the operation of our business. We do not share Sensitive Personal Information with third parties unless there is a specific purpose that you have consented to separately. Sensitive Personal Information includes the following categories:

• Health Information, such as information regarding your emotional, physical, and mental health so we can provide behavioral health services.
• Location information, such as the location of the device used to access our Services, if applicable (“Location Data”) using IP address, GPS, cellular towers and information from your mobile service provider, sensors that provide Syra Health with information on nearby devices, Bluetooth address, Wi-Fi access points, and information made available by you or others that indicates the current or prior location of your device. How we collect Location Data depends on how you use the Services.
• Financial information, such as employment status and household income to validate your account and to provide behavioral health services.
• Personal Characteristics, such as racial or ethnic origin, sexual orientation and gender identity, sexual history, and education information so that we can provide behavioral health services.

COLLECTING PERSONAL INFORMATION

We obtain the Personal Information listed above from the following categories of sources:

• Provided directly from you when you create an account or use our services, as necessary to provide our Services or respond to your requests.

• Personal Information collected automatically, whenever your visit or interact with the Services electronically, such as usage information of our Services.

• Personal Information received from other parties, such as agents or other third parties to enable the provision of our services.

HOW WE USE YOUR PERSONAL INFORMATION

Syra Health uses Personal Information, and Sensitive Personal Information to provide our Services. We may retain, share, and use your Personal Information for, the following types of activities:

• To process personal data provided by you for the intended purposes, including the provision of our services
• For analytical purposes and to research, develop, and improve programs, products, services, and content
• To personalize your experience with our Services, including marketing you have either consented to or where authorized by law. We do not send unsolicited marketing or spam.
• To prevent, detect, and fight fraud or other illegal or unauthorized activities, such as to:
  • Enforce our Terms
  • Address fraud or alleged unlawful activity
  • Assist law enforcement
  • Conduct data analysis to better understand and design countermeasures against fraud
  • Protect the security and integrity of the Services and our business
• To ensure legal compliance, such as to:
  • Comply with legal requirements
  • Enforce or exercise our rights or those of third parties
  • Due diligence and required disclosures for corporate acquisitions and sales
  • Address problems with the Services or our business

SHARING PERSONAL INFORMATION WITH THIRD PARTIES

We will only share your Personal Information as indicated in this Privacy Policy and otherwise permitted by law.

• We may share your Personal information with your consent, or at your request. We also may share your information as disclosed to you at the time of collection.
• We may share your Personal Information, including Sensitive Personal Information, with business partners or third parties, such as matched healthcare providers, electronic medical record providers, and telehealth providers, if we use those partners or third parties to perform services for our business or provide you with clinical services on our behalf.
• We may also share Personal Information (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and those of our users, business partners, or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding suspected illegal activity, fraud, or other wrongdoing.
• We may transfer your Personal Information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use Personal Information provided through the Services in a manner that is consistent with this Privacy Policy.
• In addition, we may share or use your Personal Information for any other legally permitted business purpose upon our sole discretion.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Our website may use first-party “cookies” to monitor your interactions with our website and may include Personal Information depending on how you interact with our Services. Cookies, tags, web beacons, pixels, and similar tracking technologies (collectively, “cookies”) are small data files that are sent to your browser and placed on your computer’s hard drive when you visit a website.

You do not have to accept cookies to use our website, however, some sections of our website may not work properly if you decline cookies.

Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To learn more about cookies and other tracking technologies, visit www.allaboutcookies.org.

SOCIAL MEDIA AND THIRD PARTY PLATFORMS

Certain situations or functionalities on our website may permit you to choose to cross-post or share information on a third party social media site or platform such as Facebook, Instagram, LinkedIn, Twitter, Google+, or other similar sites (collectively, “Social Media Sites”). Syra Health does not own or control such Social Media Sites, and posting your information on Social Media Sites is subject to the third party’s privacy policy and other legal terms, which may or may not provide privacy protections you agree with. Syra Health is not responsible for any act or omission of any Social Media Site, nor are we responsible for the consequences of choosing to share your information on Social Media Sites.

CHILDREN’S PRIVACY

We are committed to protecting the privacy of children. We do not direct our services to, or knowingly collect any personal information from children under the age of 13, absent explicit parental permission. If you think that a child has provided us with Personal Information, please contact us. We will use reasonable efforts to delete this information. We are not liable for any unauthorized use of our website by minors.

SECURITY

We take several steps to protect against the loss and misuse of the information under our control. Please keep in mind that no Internet transmission is completely secure. Any transmission is at your own risk. We are not responsible or liable for the illegal acts, such as hacking, by third parties. You are responsible for maintaining the security of your Syra Health account. Syra Health will treat access to the Services through your Syra Health account as authorized by you.

DATA RETENTION

We will retain your Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained and as outlined in this Privacy Policy. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide our Services to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to the enforcement of the Terms of Use, applicable statutes of limitations, litigation or regulatory investigations).

CHANGES AND OTHER SYRA HEALTH PRIVACY POLICIES

The date of this Privacy Policy was last updated is stated at the top of this Policy. As we add new features, we may revise or supplement this Privacy Policy. If we change the Privacy Policy in a material way, we will provide appropriate notice. Your continued use of the Services after such change constitutes your acceptance of the Privacy Policy, as amended. As of the date of last update, the amended Privacy Policy supersedes all previous versions of or agreements, notices, or statements about the Privacy Policy.

CONTACT US

If you have any questions, comments, or concerns regarding this Privacy Policy or the Services, or wish to exercise any of your rights, please contact us at info@syrahealth.com, or at 463-345-8950.

We reserve the right to verify your identity in connection with any requests regarding Personal Information to help ensure that we provide the information we maintain to the individuals to whom it pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that information. If you are an authorized agent making a request on behalf of a consumer, we may require and request additional information to verify that you are authorized to make that request.

We reserve the right to deny your request if we cannot verify your identity. Where we deny your request in whole or in part, we will endeavor to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

We will not restrict or deny you access to our website or services because of choices and requests you make in connection with your Personal Information. Please note, certain choices may affect our ability to deliver services or interact with you. For example, if you sign up to receive marketing communications by email, and then ask Syra Health to delete all your information, we will be unable to send you marketing communications.