Our company is committed to protecting your privacy and we take great care with your personal information. This policy will help you understand how we use and protect your data. If you have any questions, feel free to contact us at help@myflorie.com. Thank you for using Florie!

Effective Date: September 3, 2017

Referromed US, Inc. (“us,” “we,” or “Florie”) is committed to respecting the privacy rights of our customers, visitors, and other users of myflorie.com (the “Site”) and related websites, applications, services and mobile applications provided by Florie and on/in which this Privacy Policy is posted or referenced (collectively, the “Services”). We created this Privacy Policy (“Privacy Policy”) to give you confidence as you use the Services and to demonstrate our commitment to the protection of privacy. This Privacy Policy is only applicable to the Services. This Privacy Policy does not apply to any other website or digital service that you may be able to access through the Services or any website or digital services of Florie's business partners, each of which may have data collection, storage and use practices and policies that may differ from this Privacy Policy. Your use of the Services is governed by this Privacy Policy and the Agreement (as the term “Agreement” is defined in our Terms of Use). Any capitalized term used but not defined in this Privacy Policy shall have the meaning in the Agreement.

BY USING THE SERVICES, YOU AGREE TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND YOU HEREBY CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU CANNOT USE THE SERVICES. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS A PATIENT) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF.

Most of our Services require us to learn more about you so that we can best meet your needs. When you access the Services, we may ask you to voluntarily provide us certain information that personally identifies you or could be used to personally identify you (“Personal Information”). Personal Information includes (but is not limited to) the following categories of information: (1) contact data (such as your e-mail address, phone number, and practice information); (2) professional data (such as your specialty, degree, insurance plans accepted, and certification(s)); (3) insurance plans that you're subscribed to or wish to accept; and (3) other identifying information that you voluntarily choose to provide to us, including without limitation unique identifiers such as passwords, networks that you may wish to initiate or join, and Personal Information in communication that you send to us. We may also collect additional information, which may be Personal Information, as otherwise described to you at the point of collection or pursuant to your consent. You may still access and use some of the Services if you choose not to provide us with any Personal Information, but features of the Services that require your Personal Information will not be accessible to you.

When you make a payment through our Services (as further described in and subject to other provisions of the Agreement), your payment card information is processed by our payment processing partner, such as Stripe (https://stripe.com). Our payment processing partner collects your voluntarily provided payment card information necessary to process your payment. Such partner’s use and storage of the information it collects is governed by its applicable terms of service and privacy policy. The information we store includes your payment card type and the last four digits of the payment card.

2.3 Traffic Data

We also may automatically collect certain data when you use the Services, such as (1) IP address; (2) domain server; (3) type of device(s) used to access the Services; (4) web browser(s) used to access the Services; (5) referring webpage or other source through which you accessed the Services; (6) geolocation information; and (7) other statistics and information associated with the interaction between your browser or device and the Services (collectively “Traffic Data”). Depending on applicable law, some Traffic Data may be Personal Information.

Under a federal law called the Health Insurance Portability and Accountability Act (“HIPAA”), some demographic, health and/or health-related information that Florie collects as part of providing the Services may be considered “protected health information” or “PHI.” Specifically, when Florie receives identifiable information about you or your patient, this information is considered PHI.

HIPAA provides specific protections for the privacy and security of PHI and restricts how PHI is used and disclosed. Florie may only use and disclose your PHI as necessary to provide the Services. In addition, you may be asked to e-sign the Florie Business Associate Authorization (the “Florie Authorization”). Your decision to e-sign the Florie Authorization is entirely voluntary. If you choose to e-sign the Florie Authorization, you agree that Florie may use and disclose your patient’s PHI as necessary to provide the Services. These uses and disclosures are described in this Privacy Policy. To the extent any provision in the Florie Authorization is inconsistent with this Privacy Policy or other provisions of the Agreement, then the provision in the Florie Authorization only controls with respect to your patient’s PHI. If you do not e-sign the Florie Authorization, then your Personal Information is governed by this Privacy Policy and your patient’s PHI is used and disclosed only as permitted by HIPAA to provide the Services.

We collect information (including Personal Information and Traffic Data) when you use and interact with the Services, and in some cases from third party sources. Such means of collection include:

· When you use the Services’ interactive tools and services, such as creating or joining networks or editing your stored profile;

· When you voluntarily provide information in free-form text boxes through the Services;

· If you log in to certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices;

· Through cookies, web beacons, website analytics services and other tracking technology (collectively, “Tracking Tools”), as described below; and

· When you send us an email or otherwise contact us.

We may use tools outlined below in order to provide our Services to, advertise to, and to better understand users.

· Cookies: “Cookies” are small computer files transferred to your computing device that contain information such as user ID, user preferences, lists of pages visited and activities conducted while using the Services. We use Cookies to improve or tailor the Services or customize advertisements by tracking navigation habits, measuring performance, storing authentication status so re-entering credentials is not required, customizing user experiences with the Services and for analytics and fraud prevention. For more information on cookies, visit http://www.allaboutcookies.org.

· Web Beacons: “Web Beacons” (a.k.a. clear GIFs or pixel tags) are tiny graphic image files embedded in a web page or email that may be used to collect information about the use of our Services, the websites of selected advertisers and the emails, special promotions or newsletters that we send. The information collected by Web Beacons allows us to analyze how many people are using the Services, using selected publishers’ websites or opening emails, and for what purpose, and also allows us to enhance our interest-based advertising (discussed further below).

· Website Analytics: We may use third-party website analytics services in connection with the Services, including, for example, to register mouse clicks, mouse movements, scrolling activity and text typed into the Site. We use the information collected from these services to help make the Services easier to use and as otherwise set forth in Section 5 (Use of Information).These website analytics services generally do not collect Personal Information unless you voluntarily provide it and generally do not track your browsing habits across websites that do not use their services.

· Mobile Device Identifiers: As with other Tracking Tools, mobile device identifiers help Florie learn more about our users’ demographics and internet behaviors. Mobile device identifiers are data stored on mobile devices that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers enable collection of Personal Information (such as media access control, address and location) and Traffic Data.

· Cross Device Matching: To determine if users have interacted with content across multiple devices and to match such devices, we may work with partners who analyze device activity data and/or rely on your information (including demographic, geographic and interest-based data). To supplement this analysis, we may also provide de-identified data these partners.

Certain Tracking Tools used by our partners may collect information when you use the Services, such as IP address, mobile device ID, operating system, browser, web page interactions, geographic location and demographic information, such as gender and age range. These Tracking Tools help Florie learn more about our users’ demographics and internet behaviors.

Some web browsers (including some mobile web browsers) allow you to reject Cookies or to alert you when a Cookie is placed on your computer, tablet or mobile device. You may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept Florie's Cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.

You may opt out of receiving certain Cookies and certain trackers by visiting the Network Advertising Initiative (NAI) opt out page or the Digital Advertising Alliance (DAA) consumer opt-out page, or by installing the DAA’s AppChoice app (for iOS; for Android) on your mobile computing device. When you use these opt-out features, an “opt-out” Cookie will be placed on your computer, tablet or mobile computing device indicating that you do not want to receive interest-based advertising from NAI or DAA member companies. If you delete Cookies on your computer, tablet or mobile computing device, you may need to opt out again. For information about how to opt out of interest-based advertising on mobile devices, please visit http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile-device. You will need to opt out of each browser and device for which you desire to apply these opt-out features.

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that signals to websites that a visitor does not want to have his/her online activity and behavior tracked. If a website operator elects to respond to a particular DNT signal, the website operator may refrain from collecting certain Personal Information about the browser’s user. Not all browsers offer a DNT option and there is currently no industry consensus as to what constitutes a DNT signal. For these reasons, many website operators, including Florie, do not proactively respond to DNT signals. For more information about DNT signals, visit http://allaboutdnt.com.

5. Use of Information

We may use information that is neither Personal Information nor PHI (including non-PHI Personal Information that has been de-identified and/or aggregated) to better understand who uses Florie and how we can deliver a better healthcare experience at our discretion.

We use information, including Personal Information, to provide the Services and to help improve the Services, and to develop new services. Such use may include:

· Providing you with the products, services and information you request;

· Responding to correspondence that we receive from you;

· Making the Personal Information that you enter on your Florie profile page available to search engines;

· Contacting you when necessary or requested;

· Providing, maintaining, administering or expanding the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;

· Customizing or tailoring your experience of the Services, which may include sending customized messages;

· Notifying you about certain resources, Healthcare Providers or services we think you may be interested in learning more about;

· Sending you information about Florie or our products or Services;

· Sending emails and other communications that display content that we think will interest you and according to your preferences;

· Combining information received from third parties with information that we have from or about you and use the combined information for any of the purposes described in this Privacy Policy;

· Using statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts; and

· Fulfilling our legally required obligations, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.

In certain circumstances, and in order to perform the Services, we may disclose certain information that we collect from you:

· We may share your and your patients’ Personal Information with Healthcare Providers with whom you choose to interact through the Services. For example, if you invite a Healthcare Provider to join your Florie network, your Personal Information will be shared with such selected Healthcare Providers.

· Provided that you choose to use the applicable Services, we may share your and your patients’ Personal Information with applicable Healthcare Providers to enable the flow of referrals to and from your practice.

· We do not sell email addresses to third parties.

· We may share your Personal Information and Traffic Data with our partners who perform operational services (such as hosting, billing, fulfillment, data storage, security, insurance verification, Website analytics, or ad serving) and/or who make certain services, features or functionality available to our users.

· We may make certain information available to search engines if this information is not private, is aggregated or is otherwise non-Personal Information, such as your public Florie profile information and related public data.

· We may transfer your information to another company in connection with a merger, sale, acquisition or other change of ownership or control by or of Florie (whether in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

We also may need to disclose your Personal Information or any other information we collect about you if we determine in good faith that such disclosure is needed to: (1) comply with or fulfill our obligations under applicable law, regulation, court order or other legal process; (2) protect the rights, property or safety of you, Florie or another party; (3) enforce the Agreement or other agreements with you; or (4) respond to claims that any posting or other content violates third-party rights.

We may disclose information that is neither Personal Information nor PHI (including non-PHI Personal Information that has been de-identified and/or aggregated) at our discretion.

You agree that certain information will be available to search engines if this information is not private or is otherwise non-Personal Information, such as your public Florie profile information and related public data. Any information that you enter and approve on your Florie profile page, including but not limited to your name, specialty, practice name, and practice address is available to standard search engines in order to increase your visibility to other Healthcare Providers and prospective patients.

8. Storage and Security of Information

The security of your Personal Information and your patients’ PHI is of the utmost importance to us. We endeavor to follow generally accepted industry standards to protect the Personal Information and PHI submitted to us, both during transmission and in storage. For example, when you enter sensitive information on our Site, we encrypt that information using Secure Socket Layer (SSL) technology.

We store and process your and your patients’ information on our HIPAA-compliant servers in the United States. We maintain industry standard backup and archival systems.

Although we make good faith efforts to store Personal Information in a secure operating environment that is not open to the public, we do not and cannot guarantee the security of your Personal Information. If at any time during or after our relationship we believe that the security of your Personal Information may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us in your account profile. Please keep your e-mail address in your account up to date. You can update that e-mail address anytime in your account profile. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your e-mail account using your computer or mobile device and email application software.

You consent to our use of e-mail as a means of such notification. If you prefer for us to use the U.S. Postal Service to notify you in this situation, please e-mail us at help@myflorie.com.

Please include your address when you submit your request. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this e-mail address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Personal Information.

If you are a registered user of the Services, you can modify certain Personal Information or account information by logging in and accessing your account. If you wish to close your account, please email us at help@myflorie.com. Florie will delete your account and the related information at your request as soon as reasonably possible. Please note, however, that Florie reserves the right to retain information from closed accounts, including to comply with law, prevent fraud, resolve disputes, enforce the Agreement and take other actions permitted by law. You must promptly notify us if any of your account data is lost, stolen or used without permission.

10. Information Provided on Behalf of Children and Others

The Services are not intended for use by children and children are prohibited from using the Services. Florie does not knowingly collect any information from children, nor are the Services directed to children.

By accessing, using and/or submitting information to or through the Services, you represent that you are not younger than age sixteen (16), and are a health care provider or are employed by and have received express permission from a health care provider not younger than age sixteen (16) to create and receive referrals on their behalf. If we learn that we have received any information directly from a child under age sixteen (16) without his/her parent’s written consent, we will use that information only to respond directly to that child (or his/her parent or legal guardian) to inform the child that he/she cannot use the Services, and we will subsequently delete that information.

You may have arrived at the Services from, or began your use of the Services at, a third party website, including a third party website that links to Florie or embeds Florie content. The presence of such links or content on third party websites does not mean that we endorse that website, the quality or accuracy of information presented on the non-Florie website or the persons or entities associated with the non-Florie website. You may be subject to the privacy policy of the third party website as applicable and we are not responsible for the policies and practices of the third party websites. In addition, the policies and practices of third parties do not apply to your information, including Personal Information, obtained pursuant to this Privacy Policy.

The effective date of this Privacy Policy is set forth at the top of this webpage. We will notify you of any material change by posting notice on this webpage. Your continued use of the Services after the effective date constitutes your acceptance of the amended Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices. Any amended Privacy Policy supersedes all previous versions. IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING THE SERVICES AFTER THE EFFECTIVE DATE OF SUCH CHANGES.

If you have any comments, concerns or questions about this Privacy Policy, please contact us at help@myflorie.com.