Welcome to 4romeo

August 2021

Privacy Policy

Introduction

This Privacy Policy (“Privacy Policy”) describes the types of information Shakespeare Digital Health and its affiliates, including 4romeo and 4juliet entities, (collectively, “SDH,” “we,” “our,” or “us”) may collect from you or that you may provide when you visit the websites located at  www.4romeo.com, www.4juliet.com (collectively, our “Websites”) and any affiliated mobile applications (the “Apps”), and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Policy is incorporated into our Terms of Use. All capitalized terms used in this Privacy Policy but not defined herein have the meanings assigned to them in terms of Use. In addition to this Privacy Policy, SDH has established Terms of Services that set forth the general rules and policies governing your use of the website. A copy of the terms of service can be found here.

This Privacy Policy does not apply to information collected by us offline or through any other means, including on any other website operated by SDH or any third party; or any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Websites or Apps. Please read this Privacy Policy carefully. By accessing or using the Websites and Apps, 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, please do not use the Websites or Apps or provide any personal information. This Privacy Policy may change from time to time (see Revisions to Our Privacy Policy), and your use of the Websites and Apps after we make changes are deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information we collect about you and how we collect it

We collect several types of information from and about users of our Websites and Apps, including information:

• by which you may be personally identified, such as name, e-mail address, telephone number, country, or any other information collected on the Websites or Apps that is defined as personal data or personally identifiable information under applicable law (“personal information”);
• that is about you but individually does not identify you, such as whether you are a current user, product interests, or information related to your inquiry or request;
• about your internet connection, the equipment you use to access our Websites or Apps, and usage details; and/or
• about your medical condition, treatment options, physician referrals, prescriptions, and lab results, including protected health information (“PHI”) or other related health information.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the Websites. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties intermediaries, for example, the physicians, medical professionals, and pharmacies with whom we partner to provide you with services.

Information You Give to Us. The information we collect on or through our Websites or Apps may include:

• Information that you provide on our Websites or Apps. This includes information provided when you sign up for our Services when we process or respond to your inquiries related to requests for treatment, payment, customer service, and when you provide feedback on our Websites or Apps.
• Your responses to questions that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Websites and Apps and of the fulfillment of your inquiries or requests.
• Your search queries on the Websites.

Information We Collect About You. As with many other websites and mobile applications, as you navigate through and interact with our Websites or Apps, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Websites or Apps, including traffic data, location data, logs, language, date and time of access, frequency, and other communication data and the resources that you access and use on the Websites or Apps.
• Information about your computer and internet connection, including your IP address, operating the system, host domain, and browser type.
• Details of referring websites (URL). We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and may include personal information, or we may maintain it or associate it with personal information you provide to us or that we collect in other ways or receive from third parties. It helps us to improve our Websites or Apps and to deliver better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Websites or Apps according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Websites or Apps.

Cookies Used on the Websites.

Our Websites and Apps use two types of cookies: single-session (temporary) and multi-session (persistent). Temporary cookies last only as long as your web browser is open and are used for technical purposes such as enabling better navigation through our Websites or Apps. Once you close your browser, the cookie disappears. Persistent cookies are stored on your computer for longer periods and are used for purposes including tracking the number of unique visitors to our Websites and information such as the number of views a page gets, how much time a user spends on a page, and other pertinent web statistics. Cookies, by themselves, will not be used by SDH to disclose your individual identity. This information identifies your browser, but not you, to our servers when you visit the Websites or Apps. We do not respond to ‘do not track signals in your browser. We may also collect data by using “pixel tags,” “web beacons,” “clear GIFs,” or similar means (collectively, “pixel tags”) that allow us to know when you visit our Websites or Apps. Through pixel tags, we obtain non-personal information or aggregate information that can be used to enhance your online experience and understand traffic patterns. Information We Receive From Other Sources. This is the information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, third parties intermediaries, such as the physicians, medical professionals, and pharmacies with whom we partner to provide you with services, sub-contractors in technical, advertising networks, analytics providers, and search information providers).

How We Use Your Information

In connection with providing you with the Websites, Apps, and Services, we may use, compile, analyze, and save your information in the following ways:

• To carry out the Services and, as applicable, facilitate the provision of health care services to you by physician or other health care provider and ensure that the physicians or health care providers have the services and support necessary for health care operations.
• To communicate with you about the Websites, Apps, and Services, or your use of the Websites, Apps, and Services, and send you communications on behalf of physicians or other health care providers utilizing the Services to meet your needs.
• To provide you with information that you have requested or to respond to your inquiries.
• To provide you with technical support and to improve our Websites, Apps, and Services.
• To verify your identity and administer your account, including processing your payments and fulfilling your orders.
• In order to ensure that content from our Websites and Apps is presented in the most effective manner for you and for your computer or mobile phone, to allow you to participate in interactive features of our Services (when you choose to do so), and as part of our efforts to keep our Websites and Apps safe and secure.
• To communicate with you about our products and services and those of our subsidiaries, affiliates, and parent companies and any of their related businesses, and those of our third-party partners.
• To measure or understand the effectiveness of advertising, we serve you and others and deliver relevant advertising to you.
• In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personal information that you provide and other information concerning your relationship with us.
• To notify you about changes to our Websites, Apps, or Services.
• For any purpose where you have given your consent (where legally required).
• To comply with applicable federal and state law.

Information We Receive From Other Sources. We will combine information we receive from other sources with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of Your Information

We may disclose aggregated, de-identified information about our users and information that does not identify any individual without restriction. We may disclose your personal information to third parties in connection with the provision of our Services or as otherwise permitted or required by law. You agree that we have the right to disclose personal information that we collect or you provide as described in this Privacy Policy, including:

• To any member of our group, which means our subsidiaries and affiliates, including our ultimate holding company and its subsidiaries.
• To health care providers (i) to schedule and fulfill appointments and provide health care services as part of the Services, (ii) to whom you send messages through our Services, and (iii) for other treatment, payment, or health care operations purposes, including pharmacy services, upon your request.
• To health care organizations, pharmacies, contractors, service providers, and other third parties we use to support our business or in connection with the administration and support of the Services.
• To our third-party service providers that provide services such as hosting our Websites or Apps, data analysis, IT services and infrastructure, customer service, e-mail delivery, auditing, and other similar services.
• To any third parties, we believe it necessary or appropriate to comply with applicable laws.
• 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 SDH’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by SDH about our Website or App users is among the assets transferred.
• To fulfill the purpose for which you provide it. For example, if you email us asking us to contact a third party (including a medical professional), we may transmit the contents of your email to the recipient.
• For any other purpose disclosed by us when you provide the information or with your consent.
• If we are under a duty to disclose or share your personal information to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; or to protect the rights, property, or safety of SDH, our customers, or others. This may include 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 strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information. Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Websites or Apps may then be inaccessible or not function properly. Do Not Track. We do not currently respond to “do not track” signals as we do not track our customers across third-party websites. Promotional Offers from SDH. If you do not wish to have your contact information used by SDH to promote our own products or Services, you can check certain boxes on the forms we use to collect your data. You can also always exercise your right to ask us not to process your personal information for marketing purposes by contacting us at the address below. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. 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.

Accessing, Correcting & Deleting Your Information

You may contact us at the address below—or by emailing  info@4romeo.com or info@4juliet.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. If SDH deletes your user account, medical providers and other affiliates may still have the right to retain information as required by applicable law, regulations, or their own retention policy. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Unless otherwise required by law, SDH will also erase personal information when the personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; when you withdraw your consent (where the lawfulness of processing was based on your consent), and there is no other legal ground for the processing; when you object to the processing, and there are no overriding legitimate grounds for the processing; when your personal information has been unlawfully processed; and when it is necessary to comply with legal obligations.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Websites and Apps, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. The information you share in public areas may be viewed by any user of the Websites or Apps. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our Websites or Apps; any transmission is at your own risk.

Third Parties

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices, including data privacy and security process and standards of any third parties, including physicians and other health care providers using the Services, the manufacturer of your mobile device and other IT hardware and software, and any other third-party mobile application or website to which our Websites, Apps, or Services may contain a link. These third parties may at times gather information from or about you. We have no control over the privacy practices of these third parties. Even though 4Romeo & 4Juliet may not be a “covered entity” as defined in HIPAA, any physician or other health care provider engaging through our Services may be a “covered entity” and therefore subject to the provisions of HIPAA from time to time. If you are using the Services, your acceptance of the Terms of Use and this Privacy Policy incorporates your acceptance and consent to the SDH Professionals Notice of Privacy Practices included on the Websites. This notice describes how your physician or other health care provider uses and discloses your PHI. SDH has agreed that its collection, use, and disclosure of your PHI on behalf of your physician or health care provider will be done consistent with the SDH Professionals Notice of Privacy Practices except to the extent you have expressly authorized additional uses and disclosures.

Use by Minors

If you are under 18 years of age, we must obtain valid and verifiable consent by your parent or legal guardian to this Privacy Policy and our Terms of Use before you can use Websites, Apps, and Services. Such consent will be obtained via reasonable methods, as determined by us at our sole discretion. If we determine that the consent obtained is inadequate, we will notify you, and you may not use or access the Websites, Apps, or Services at any time or in any manner. However, if you are a parent, legal guardian, or personal representative of a minor child under 18 years of age, you may, in compliance with the Terms of Use, use our Services on behalf of such minor child. Any information you provide us on behalf of your minor child will be treated in accordance with this Privacy Policy. We do not knowingly collect information for individuals under the age of 18 for whom we have not obtained adequate consent pursuant to the above. If we learn that we have received any information for an individual under the age of 18 for whom we have not obtained adequate consent pursuant to the above, we will only use that information to respond directly to that child (or a parent, legal guardian, or personal representative) to inform him or her that he or she cannot use our Service, and subsequently, we will delete that information from our own servers.

California Residents

California law requires us to provide additional information regarding how we collect, use and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). Additional information for California residents can be found at [HYPERLINK TO PRIVACY POLICY FOR CALIFORNIA RESIDENTS].

Revisions to Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy posted on this page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically monitoring and reviewing any updates to the Privacy Policy. Your continued use of our Websites or Apps after such amendments will be deemed your acknowledgment of these changes to this Privacy Policy.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at:

SDH

324 Peterson Rd.

Libertyville, IL 60048

Attn: Privacy Officer

HIPAA Privacy Notice

HIPAA PRIVACY NOTICE THE FOLLOWING NOTICE DESCRIBES HOW YOUR MEDICAL INFORMATION MAY BE USED AND DISCLOSED, AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW THE INFORMATION CAREFULLY.

• Your confidential healthcare information may be released to other healthcare professionals within the organization for the purpose of providing you with quality healthcare.
• Your confidential healthcare information may be released to your insurance provider for the purpose of the organization receiving payment for providing you with needed healthcare services.
• Your confidential healthcare information may be released to public or law enforcement officials in the event of an investigation in which you are a victim of abuse, a crime, or domestic violence.
• Your confidential healthcare information may be released to other healthcare providers in the event you need emergency care.
• Your confidential healthcare information may be released to a public health organization or federal organization in the event of a communicable disease or to report a defective device or untoward event to a biological product (food or medication).
• Your confidential healthcare information may not be released for any other purpose than that which is identified in this notice.
• Your confidential healthcare information may be released only after receiving written authorization from you. You may revoke your permission to release confidential healthcare information at any time.
• You may be contacted by the organization to remind you of any appointments, healthcare treatment options, or other health services that may be of interest to you.
• You may be contacted by the organization for the purposes of raising funds to support the organization’s operations. You have the right to restrict the use of your confidential healthcare information. However, the organization may choose to refuse your restriction if it is in conflict with providing you with quality healthcare or in the event of an emergency situation.
• You have the right to receive confidential communication about your health status.
• You have the right to review, photocopy and/or receive electronic copies of any/all portions of your healthcare information.
• You have the right to make changes to your healthcare information.
• You have the right to know who has accessed your confidential healthcare information and for what purpose.
• You have the right to possess a copy of this Privacy Notice upon request. This copy can be in the form of electronic transmission or on paper.
• The organization is required by law to protect the privacy of its patients. It will keep confidential any and all patient healthcare information and will provide patients with a list of duties or practices that protect confidential healthcare information.
• You will be notified if the confidentiality of your healthcare information is breached.

The organization will abide by the terms of this notice. The organization reserves the right to make changes to this notice and continue to maintain the confidentiality of all healthcare information. Patients will receive a mailed copy of any changes to this notice within 60 days of making the changes.

• You have the right to complain to the organization if you believe your rights to privacy have been violated. If you feel your privacy rights have been violated, please mail your complaint to the organization:

ATTN: HIPAA Privacy Officer
CarePartners Pharmacy, LLC
326 Peterson Road, Libertyville, IL 60048

All complaints will be investigated. No personal issue will be raised for filing a complaint with the organization. For further information about this Privacy Notice, please contact 866-832-7171. This notice is effective as of the Date of Effectiveness. This data must not be earlier than the date on which the notice is printed or published.

Informed Consent Regarding Use of Telemedicine / E-Visit Services

Date Of Last Revision: July 2019

This Consent is provided by CarePartners Pharmacy, LLC and its affiliates, including 4Romeo and 4Juliet entities, (collectively, “CPP,” “we,” “our,” or “us”)

Purpose

The purpose of this form is to provide you with information about telemedicine / e-visit and to obtain your informed consent to participate in a telemedicine / e-visit health service as part of your medical care.

Nature of telemedicine / e-visit

Telemedicine / e-visit involves the use of electronic communications to enable a health care provider and a patient at different locations to share medical information for the purpose of evaluation, diagnosis, consultation, or treatment of the patient. The delivery of healthcare via telemedicine / e-visit allows the patient and provider to establish a relationship, much as they would during a traditional face-to-face appointment. For example, your telemedicine / e-visit encounter may include interaction through and with the use of the internet, recorded audio communications, physical examinations, medical imaging, medical tests, and diagnoses, as well as related technologies known as “store-and- forward.”

Benefits

The benefits of telemedicine / e-visit include improved access to medical services and care, including the expertise of specialists and consultants that may not otherwise be available to you. Telemedicine / e-visit also permits increased efficiency in evaluations, diagnoses, consultations, and treatment.

Potential Risks

The potential risks associated with the use of telemedicine / e-visit are rare, but include delays in medical evaluation and treatment due to equipment failures or information transmission deficiencies (such as poor image resolution); breach of privacy of protected health information due to security breaches or failures; and adverse drug interactions, allergic reactions, complications, or other errors due to patient’s failure to provide complete medical information or records.

Indemnification

YOU AGREE TO INDEMNIFY AND HOLD HARMLESS CarePartners Pharmacy LLC, ITS EMPLOYEES, AGENTS, DIRECTORS, MEMBERS, MANAGERS, SHAREHOLDERS, OFFICERS, REPRESENTATIVES, ASSIGNS, PARENTS, PREDECESSORS, AND SUCCESSORS FROM AND AGAINST ANY AND ALL LOSS, DAMAGE, EXPENSE, LIABILITY, CLAIM, OR DEMAND WHATSOEVER, ARISING OUT OF OR RELATED TO ANY FAILURE OF TECHNOLOGY OR EQUIPMENT IN CONNECTION WITH THE PROVISION OF TELEMEDICINE / E-VISIT WHETHER OR NOT ANY SUCH LOSS, DAMAGE, EXPENSE, LIABILITY, CLAIM, OR DEMAND ARISES FROM OR RELATES TO CarePartners Pharmacy’s NEGLIGENCE.

Alternatives

Alternative methods of care may be available to you, such as in-person services. Your provider will explain any such options to you, and you may choose an alternative at any time.

Follow-up Care & Emergency Situations

In some situations, telemedicine / e-visit is not an appropriate method of care. If there is an urgent situation, if you have an adverse reaction, if a technical failure prevents you from communicating with your telemedicine provider, or if you believe telemedicine / e-visit will not provide sufficient safety and quality, you should contact CarePartners Pharmacy LLC at 866-832-7171 (Mon-Fri 8:30am to 5:30pm CST). If the contacts listed below are unavailable, you must seek care at an emergency room facility or other provider equipped to deliver urgent or emergent care. If the situation is an emergency, call 911.

Your Privacy Rights

CarePartners Pharmacy LLC uses network and software security protocols to protect the confidentiality of your patient health information, including for example your medical record, EMR, imaging, and personal financial data. These protocols are designed to safeguard the data and to ensure its integrity against corruption. Personal information that identifies you or contains protected health information will not be disclosed to any third party without your consent, except as authorized by law for the purposes of consultation, treatment, payment/billing, and certain administrative purposes, or as otherwise set forth in CarePartners Pharmacy’s Notice of Privacy Practices.

By signing this form, I agree to the following

Telemedicine / e-visit is the use of electronic information and communication technologies by a health care provider to deliver services to an individual when he/she is located at a different site than the provider. I understand that I need to provide a full and accurate medical history, including any pre-existing conditions, to my telemedicine / e-visit provider so that my provider can accurately determine what services I need. I further understand that my provider will determine whether telemedicine / e-visit is appropriate for me at this time, based on the condition being diagnosed and/or treated. I understand that I may benefit from telemedicine / e-visit, but that results cannot be guaranteed.

My provider will inform me who will be present at the provider’s location during the telemedicine / e-visit service and I have the right to exclude anyone from being present, if I so choose. I further understand that I have the right to object to the use of a telemedicine / e-visit service without prejudice to any future care or treatment and without risking the loss or withdrawal of any health benefits to which I am entitled. If there are costs to me associated with my telemedicine / e-visit encounter, a health care professional will discuss those costs with me prior to the start of my session.

Further, I understand and agree that I must pay the full amount of the costs associated with this telemedicine / e-visit service, including any prescription I may receive, and I will not attempt to submit a claim to Medicare, any other federal payor, or any state or private insurer. I understand that the laws that protect privacy and the confidentiality of medical information also apply to telemedicine / e-visit and I agree that CarePartners Pharmacy may provide my confidential personal health information to other medical providers who may be located in other areas, including on rare occasions to providers outside the State, as necessary. I have the right to inspect and obtain copies of all information received and recorded during any telemedicine / e-visit session, subject to the policies of the physicians, physician assistants, nurse practitioners and facilities involved in my care. I may be charged a fee for copies of my records in accordance with applicable State rules. I have read and understand the information above, and all of my questions have been answered to my satisfaction.

All photos and images used are licensed images and not actual patients unless expressed otherwise.

If you have a concern about a medical professional, you may contact the Medical Board in your state regarding your concerns.

I consent to a CarePartners Pharmacy LLC physician, physician assistant, or nurse practitioner to provide services o me via telemedicine / e-visit.

By clicking “I Agree”, I understand and consent to the foregoing acknowledgements and disclosures including CarePartners Pharmacy LLC Terms of Service and Notice of Privacy Practices.

You are free to obtain your prescription from any pharmacy of your choice. You are free to obtain your medical examination from another healthcare provider that is not associated with CarePartners Pharmacy LLC.

CarePartners Pharmacy will use its pharmacy to fulfill your order directly to your door. You are free to obtain your prescription from any pharmacy of your choice by contacting our support team. Further, for purposes of this informed consent, MY ACT OF CLICKING “I Agree” SHALL CONSTITUTE AND IS MY ELECTRONIC SIGNATURE.