Privacy Statement

Last modified: December 10, 2024

We do not sell your personal information.

1. General

Passport Health (“we”, “us” or “Passport Health”) operate the website located at www.PassportHealthUSA.com, as well as the Passport Health mobile application (collectively, the “Site”). We respect the privacy of every individual who visits the Site. This Privacy Statement outlines the types of information we collect when you use the Site, how we use that information, and the circumstances under which we may share that information.

This policy applies to information we collect:

• On this Site.
• In email, text, and other electronic messages between you and this Site.
• Through mobile applications you download from the Site or which we offer relating to the Site, which provide dedicated non-browser-based interactions between you and the Site.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by us or any third party, or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from the Site.

This Statement will also tell you what to do if you do not want your personal information collected or shared by us. If you have any questions about how we collect, use and share your data, please email us at
privacy@passporthealthusa.com.

2. Your Acceptance of These Terms

Passport Health reserves the right to change its practices at any time, may update the Privacy Statement at any time and has no obligation to provide you actual notice of these changes. If we do choose to update our privacy practices, we will also update this Privacy Statement accordingly. By using the Site, you signify your consent to our Privacy Statement. If you do not agree with this Statement, please do not use the Site. Your continued use of the Site following the posting of changes to its terms means you accept those changes, and you are responsible for periodically visiting the Site to check for any changes to this Statement. If we make any material changes to how we treat our users’ personal information, we will notify you by publishing a notice on the homepage of the Site. The date this Statement was last revised is identified at the top of this page.

3. Personally Identifiable Information

Personally identifiable information is defined as information that can be used to trace an individual’s identity. Certain types of personally identifiable information exist standing alone, such as your name or social security number. Other types of information turn into personally identifiable information when they are combined with other identifying information that can be linked to a specific individual, such as a date and place of birth or your mother’s maiden name.

There are certain cases where, when you interact with the Site, we may ask you for personally identifiable information. The type of information we collect through the Site may include:

• Information that you provide by filling in forms on the Site. This includes information provided at the time of requesting further services from us. We may also ask you for information if you report a problem with our Site.
• Records and copies of your correspondence (including email addresses) if you contact us.
• Your responses to surveys that we might ask you to complete for customer service purposes.
• Details of transactions you carry out through the Site, including the fulfillment of your medication dispensing requests.

If you visit any of our clinics in-person for any reason, we may use your personally identifiable information to contact you regarding your appointment, or any follow-up after the appointment has concluded.

Personal information does not include publicly available information from government records, or deidentified or aggregated customer information.

We will not collect any personally identifiable information about you unless you provide it to us voluntarily.

Disclosure of your PII
When you provide us with personally identifiable information, Passport Health may:

• store and process that information to better understand your needs, customize your experience, and improve our products and services;
• use that information to contact you via email, text message and postal mail for informational, marketing, and promotional purposes;
• disclose that information to third parties when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) Passport Health’s rights or property, other users of the Site, or anyone else that could be harmed by such activities; and
• disclose that information to third parties when we believe in good faith that the law requires it.

We limit the ways in which we use the information you provide to us. Except as stated in this Privacy Statement, or as otherwise stated at the time the personally identifiable information is gathered, we will not provide personally-identifiable information to third parties. However, certain non-personally identifiable user information may be provided in aggregate form to third parties for legitimate business purposes other than identifying you.

4. Sensitive Personal Information

Some of the information we may ask you for and collect when you provide it to us may be categorized as “Sensitive Personal Information.” This type of information will be sought in rare circumstances, and only in ways which should be obvious to you why and how we are asking for the SPI. In the context of this Site, possible SPI includes personal information that reveals:

• your social security, driver’s license, state identification card, or passport number;
• account log-in, financial account, debit card, or credit card numbers in combination with any required security or access code;
• password, or credentials allowing access to an account;
• precise geolocation;
• racial or ethnic origin; or
• health-related data.

5. Financial Information

Passport Health may ask you for your credit card number and related personal financial information when you order goods or services from our Site or when you book an appointment online. We will use your credit card information for processing orders and/or reserving your appointment. We may share this information with credit card processing companies and any other third party that may need the information to process your orders. These organizations have their own privacy and data collection practices, and we have no responsibility for these independent policies. Currently, we use Clover for our payment processing in person. Their privacy statement and related policies can be found here. We also use CardConnect for payments on the Passport Health online store. Their privacy statement and related policies can be found here.

6. Non-Personally Identifiable Information

Passport Health may collect information about you that is not personally identifiable. This type of information includes your zip code, area code, and preferences. We will not collect any such information about you unless you provide it to us voluntarily. We may share this information in the aggregate with advertisers, business partners, and other third parties. For example, we may inform a business partner that our clients are X% females and Y% males. This type of non-identifiable data is used by us and our vendors to customize our content. We may also use the data to make visits to the Site easier, quicker, and better for you and our other users.

We also may track certain information about your visit to the Site, including (without limitation) pages viewed, clickstreams, and searches. Such information is gathered in aggregate and is not linked to any specific users. Our explanation about this tracking is explained in further detail in our Automatic Data Collection Statement.

7. Disclosure of Your Information

We may disclose aggregated information about our users, which does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business, and
  who are bound by contractual obligations to keep personal information confidential and use it only
  for the purposes for which we disclose it to them.
• 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 Passport Health’s assets,
  whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Passport Health about our users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide us with the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Passport Health, our customers, or others.

8. Creation Of A User Account

You do not need to create an account on the Site in order to access the Site. However, in the future, we may choose to facilitate the creation of user accounts, and we may cause certain content on the Site to not be accessible to you if you do not create an account.

If you create an account, we will collect certain PII from you directly, and we may indirectly collect additional PII from you in connection with the creation of your user account. Additional data may be collected from you and associated through your account, like what locations you are looking at to visit a Passport Health clinic and where you are interested in traveling to. We may also collect other information you provide to us in connection with using our search feature while logged into your user account, including specific information relating to the search or types of searches you perform while using the Site.

9. Information Collected Automatically

Passport Health may automatically collect non-personally identifiable information about your use of the Site, such as the domain from which you access the Internet (for example, aol.com, if you are connecting from an America Online account), the date and time you access the Site, and the Internet address of the website from which you linked directly to our Site. This information will not be linked to personally-identifiable information. We may use this information to analyze and enhance our Site and for security purposes, and we may aggregate this information and share the aggregated information with business partners, sponsors, and other third parties.

10. Modification of Information and Opt-Out

We respect your time (and your inbox) and honor CAN-SPAM. If you register to receive emails from us, we may occasionally send you emails about products and services we believe may be of interest to you. If you do not want to receive these emails, you should click on “Unsubscribe” at the bottom of the email. We will honor all opt-out requests within 10 business days, if not sooner.

11. Your State-Specific Data Privacy Rights

Certain states have unique requirements regarding our disclosure of data practices, while other states offer extra personal data rights and protections. As of the date of this Statement, the states that have specific data privacy or disclosure laws are as follows: California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland (effective 10/1/2025), Minnesota, Montana, Nebraska, New Hampshire (effective 1/1/2025), New Jersey, Oregon, Rhode Island (effective 1/1/2026), Tennessee, Texas, Utah and Virginia. For a current guide of state-specific privacy laws, you can go here. If you are a resident of any of these states, you may have additional privacy rights available to you that are not generally set forth in this Statement. This list of states with specific privacy laws is constantly changing, and this Statement may not reflect the current list of states with such laws.

Each of these states provide, either now or in the future, residents of their states with the rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).
• Data portability.
• Opt-out of personal data processing for:
• targeted advertising (excluding Iowa);
• sales; or
• profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
• Either limit (opt-out of) or require consent to process sensitive personal data.

Exercising Your Rights
The exact scope of these rights may vary by state. To exercise any of the rights described above, please submit a request by either:

• Calling us at (844) 224-3177
• Filling out the online form here.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may also make a request to know or delete on behalf of your child by contacting us in the same manner as directed above, and providing additional information with respect to the data you are seeking for your child, including specific identifying information so we can verify the relationship.

To appeal a decision regarding a consumer rights request, please email us directly at Privacy@PassportHealthUSA.com, with a subject line of “Consumer Privacy Rights Appeal”, and follow the procedure for your state of residence for such an appeal.

12. Child Online Privacy Protection Act (COPPA)

The Site is not directed at individuals under thirteen years of age, and Passport Health does not intend to collect any personally identifiable information from such individuals through the Site. However, a parent or guardian may use the Site to make an appointment for a child under the age of thirteen, and if the parent or guardian makes such an appointment, they may be required to submit PII for the child.

13. Links to Third-Party Websites

Although we do not currently have any third-party vendors with access to the Site, we may in the future allow some third-party vendors to have links on the Site that take you to other websites not owned or controlled by us. Those external third-party websites may collect personally identifiable information about you. This Privacy Statement does not cover third-party data collection practices. Passport Health has no control over, and no responsibility for, the data collection practices of any third-party website which you may visit after visiting this Site.

14. Our Site Security

Securing all personally identifiable information associated with our users is of the utmost concern to us. Unfortunately, we can’t ensure or warrant the security of any information you transmit to us or receive from our online products or services, and you choose to undertake those transmissions at your own risk. Once we receive your personally identifiable information, we will take reasonable efforts to ensure its security on our systems.

15. Passport Health Mobile Application

Passport Health has developed a mobile application for consumers who are interested in accessing their electronic health records through their phone or tablet. Our app requires you to provide and transmit certain personally identifiable information when creating an account. This information falls under the Personally Identifiable Information section of this Privacy Statement. In addition, users of our app will have the ability to download their health records as well as upload their own supplemental documentation. This action will require that our app have access to your device’s internal storage to complete the download or upload request.

Our app allows users to view previous and upcoming appointments, and to add upcoming appointments to your device’s calendar application. Our app will need to access your device’s calendar to read the data and then create the appointment on the calendar. Our app does not use any of your calendar data outside of the intended in-app functionality, nor do we share this user data with any third parties.

16. Contact Information

If you have questions or concerns regarding this Privacy Statement and its enforcement by Passport Health or its employees, you can contact Passport Health at:

Privacy Issues
c/o Passport Health
4343 N. Outlier Blvd.
Phoenix, AZ 85008

Privacy@PassportHealthUSA.com
DPO@PassportHealthGlobal.com