Legal and Privacy

Digital Privacy Policy

Welcome!

You have arrived at a digital service location (i.e., website or application) that is owned and operated by Village Practice Management Company, LLC (“VillageMD” or “We”). VillageMD is composed of various entities that provide healthcare and related services to individuals throughout the United States of America. The following entities make up the VillageMD family:

• Village Medical Primary Care Clinics*
• Village Medical at Walgreens
• Village Medical at Home
• Village Medical Pharmacy
• Village Medical Physical Therapy

This Privacy Policy governs your use of any digital service location that posts a link to this Privacy Policy, and also applies to your use of interactive features, widgets, plug-ins, applications, content, downloads and other services (collectively the “Service”) that VillageMD owns and controls and makes available through an online service OR where VillageMD posts a link to this Privacy Policy, regardless of how you access or use the Service, whether via personal computers, mobile devices or electronic media.

PLEASE READ THE COOKIE STATEMENT BELOW CAREFULLY BEFORE USING OR OBTAINING ANY MATERIALS, INFORMATION, PRODUCTS OR SERVICES THROUGH THE SERVICES. BY ACCESSING
THE SERVICES, YOU AGREE TO ACCEPT, WITHOUT LIMITATION OR QUALIFICATION, THIS COOKIE STATEMENT BELOW.

We reserve the right to change, update or correct any of this Cookie Statement, or any information contained in the Services, at any time without advance notice by posting an amended statement to the Services. Your continued use of the Services means that you accept and agree to the revised Cookie Statement. If you do not accept this Cookie Statement (as amended from time to time), please exit the Services immediately.
To the extent we provide you notice on our Service of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use. By using our Service, you consent to our Privacy Policy and our collection, use and sharing of your information and data, and other activities as described below.

The Information We Collect
Our web servers automatically capture your domain name, the IP address of the web page from which you enter our Service, browser type, the pages you visit on our Service, the amount of time you spend here, and other relevant information about your visit. We do not collect any information that can reveal your personal identity unless you voluntarily provide it when you register to use an interactive feature of the Service. Any health data that may be collected would be based on your self-report of your health data or data from a remote patient monitoring device(s) (an “RPM Device”) you connected to the Service. Some examples of health data that you may self-report or is received directly from an RPM Device includes, but is not limited to respiratory rates, blood pressure, height, and weight. The information we collect is not part of any designated record set. If you use and continue to use the features on a Service, you are “opting in” and agree to our collection of information as described above. You may “opt out” each time you access the Service. If you “opt out,” you cannot use the interactive features and no information is collected or maintained by VillageMD. If you wish to opt out after you have used the features on a Service, please contact us at contact@villagemedical.com. It may take up to thirty (30) days to ensure that such information is no longer collected and remove any of your deleted from our files (excludes information from the Service that may be included in your patient medical record).

Use of the Information this Service Gathers/Tracks
Any personally identifiable information you give us will be used only as permitted by law, including to provide the product, service, or information you have requested or to support the program(s) for which you registered. Unless you expressly consent to let us do so, your personally identifiable information, including your e-mail address, will not be sold, rented, licensed, or otherwise shared with third parties. Additionally, unless you expressly provide your consent or to fulfill a request from you, we won’t send you any unsolicited email. The non-personally identifiable information we gather in aggregate form may be used to improve our Service, and we may share that information with business partners, third-party vendors working on our behalf, or our health and wellness sponsors. The use and collection of information by these third-party vendors is governed by their respective privacy statements, and is not covered by this Privacy Policy or the VillageMD Terms of Use. To protect your information, we encourage you to learn about the privacy policies of those third parties. Third-party vendors that VillageMD has a current business relationship with include the entities listed
here:

• Google Analytics. We use Google Analytics for tracking queries submitted to their search engines. We also use Google’s DoubleClick technology for tracking our advertisements, enabling “tell-a-friend” social media functionality, and providing us with the contact information of users who submit a request for additional information about our services via click-through advertisements. View Google's privacy policy.
• Media Contacts & Influencers. VillageMD obtains contact details and other personal information regarding media contacts and influencers from a variety of sources, including Cision. If you wish to know more about how such information is collected and used, please refer to Cision’s privacy notice.
• Adobe Advertising Cloud. We use Adobe’s Advertising Cloud conversion tracking solution to track visitor engagement with our advertisements and campaigns. View Adobe’s privacy policy.

This list may be updated and modified from time to time by VillageMD, at its sole and absolute discretion and with no advance or formal written notice to you.

Information that you voluntarily provided will be maintained as long as VillageMD deems appropriate to fulfill the purpose for which you provided the information, until you request us to remove it, or for as long as permitted or required under applicable law.

We may offer sweepstakes, contests, and other promotions (for any, a “Promotion”) through the Service that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, personal information may be disclosed to third parties or the public in connection with the administration of such Promotion, including in connection with winner selection, prize fulfillment and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to (1) protect or defend the rights, safety or property of VillageMD or third parties (including through the enforcement of this Privacy Policy, and other applicable agreements and policies); or (2) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have complete discretion, and without notice to you, to elect whether or not to make such disclosures, and to contest or not contest requests for such disclosures.

Third-party Analytics Providers and Ad Servers
We may use third-party vendors to perform certain services on behalf of us or the Service, such as hosting the Service, designing and/or operating the Service’s features, tracking the Service’s activities, using sharing technology that allows users to share content on this Site through social media, and analytics. We may provide these vendors with access to user information, or they may directly collect your information to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own tracking technologies on your device, and they may otherwise collect or have access to information about you, potentially including personal information. We are not responsible for those third-party technologies or activities arising out of them. We may also work with certain third parties to provide us with information regarding traffic on the Service to serve advertisements elsewhere online, and to provide us with information regarding the use of the Service and the effectiveness of our advertisements. These third parties may automatically collect information about you using their own cookies or other technologies, or may otherwise collect or have access to information about your visits to this Service and other websites, your IP address, your ISP, the browser you use to visit a Service and other usage information. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our website and the other sites tracked by these third parties.

The Cookie Statement
When you visit the Service, we may place a temporary “session” or a permanent cookie on your computer that will allow us to customize and enhance your experience at the Service, make improvements to our Service or report Service activity. Our session cookies are not permanently stored on your computer, and they expire when you leave. Permanent cookies are issued to Service visitors who link to the Service from a search engine, and are used only to permit VillageMD to attract qualified users to the Service. Our cookies are not used to send spam. We store cookie information in aggregate form and use the aggregate information to make improvements to the Service, or in internal reports on Service activity. You may opt out of allowing cookies to be placed on your computer. Refusing cookies disables our ability to include information about your visit in our regular monitoring of Service traffic.

Cookies and Similar Technology Policy
What are cookies?
A cookie is a small amount of data sent from a web server to your browser and stored on your computer’s or mobile device’s hard drive while you are viewing the website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our website. This type of information is collected to make the Service more useful to you and to tailor your experience with us to meet your special interests and needs. We use and store this information to provide you with more personalized and customized online services and to make our site more convenient, useful, valuable and appealing to you. We use two broad categories of cookies: (1) first-party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our website; and (2) third-party cookies, which are served by service providers on our website, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

Cookies We Use
The Service may use the following types of cookies for the purposes set out below:

Disabling cookies

If you decide at any time that you no longer wish to accept cookies from a Service for any of the purposes described above, you can typically instruct your browser, by changing its settings, to remove or stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. In order to do this, consult your browser’s technical information (instructions are usually located within the “settings,” “help,” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. If you do not accept our cookies, you may experience some inconvenience or not be able to use all portions of the services or all functionality of the services.

Pixel tags

In addition, we may use pixel tags (also referred to as clear GIFs, web beacons or web bugs) on the Service to track the actions of users on website. Pixel tags are tiny graphic images with a unique identifier, similar in function to cookies, that are used to track online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, pixel tags are embedded invisibly in web pages. Pixel tags also allow us to send email messages in a format users can read, and they tell us whether emails have been opened, for example, to ensure that we are sending messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user.

“Do Not Track” signals

Some internet browsers may be configured to send “Do Not Track” signals to the online services you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com

Sites We Link To

If you choose to use any of the links we provide to providers, sponsors, and other third-party resources, you will be leaving our Service and going to a new website. While we take care in choosing the content and links on our website, we accept no liability whatsoever for third-party sites. Protection of your privacy at those other sites will be governed by the privacy policy at that site. We’ve taken special care selecting the companies that are accessible through our website to try to ensure they respect your privacy as we do, but please take the time to read the privacy policies at their sites.

What Should Parents Know about Children?
We understand the importance of protecting children’s privacy in the interactive world. We do not use the Service to knowingly collect personal information from children under the age of thirteen (13) without parental consent. If you are a child under thirteen years of age, you are not permitted to use the Service and should not send any information about yourself to us through the Service.

In the event that we become aware that we have collected personal information from any
child, we will dispose of that information in accordance with the Children’s Online Privacy Protection Act and other applicable laws and regulations. If you are a parent or guardian and you believe your child under the age of 13 has provided us with information without your consent, please contact us at contact@villagemedical.com. It may take up to thirty (30) days to ensure that such information is no longer collected and that such information is deleted from our files.

Changes to this Policy

If we make any changes to this Privacy Policy, we will let you know the effective date of the
changes and you can contact our Webmaster if you would like to know more about what’s new.

If you have any questions or comments or receive any unwanted e-mail from this Service, please contact our Webmaster via e-mail at contact@villagemedical.com.

Disclaimer

ELECTRONIC COMMUNICATIONS PRIVACY ACT NOTICE (18 U.S.C. 2701-2711): OWNER MAKES
NO GUARANTY OF CONFIDENTIALITY OR PRIVACY OF ANY COMMUNICATION OR INFORMATION
TRANSMITTED ON THE WEBSITE OR ANY OTHER WEBSITE LINKED TO THE WEBSITE. VILLAGEMD
WILL NOT BE LIABLE FOR THE PRIVACY OF INFORMATION, E-MAIL ADDRESSES, REGISTRATION
AND INDENTIFICATION INFORMATION, DISK SPACE, COMMUNICATIONS, CONFIDENTIAL
INFORMATION OR TRADE SECRET INFORMATION, OR ANY OTHER CONTENT TRANSMITTED
OVER NETWORKS ACCESSED BY THE WEBSITE, OR OTHERWISE CONNECTED WITH YOUR USE OF
THE WEBSITE.

*For more information about our Village Medical Primary Care Clinic locations, please visit https://www.villagemedical.com/locations

Compliance Statement

Village Medical is committed to conducting business honestly, ethically, and in accordance with all applicable laws and regulations. Village Medical has a robust compliance program, which includes all of the seven elements recommended by the Office of Inspector General including policies, training, and event management, among others.

The compliance training program includes our Working Smarter podcast, which is available on Apple, Spotify, or wherever you get your podcasts.

The VillageMD Compliance and Privacy Officer is Wendy Rubas.

We are always striving to do better. Any person can report a tip or compliance concern in one of two ways:

1. By emailing: sharon@villagemd.com
2. By calling the Compliance Hotline at 1-855-236-0714. Callers cannot be identified and calls are not recorded