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Privacy Policy

At New Dawn Labs Inc., and its affiliates (collectively "New Dawn", "we", "us", "our"), we respect your privacy and take Internet privacy very seriously. In this Privacy Policy, we would like to tell you what personal data we collect, what we use it for and when it may be disclosed.

In the context of your use of New Dawn's Services (as defined in the Terms of Service), we provide and make available certain websites, including, without limitation, www.newdawn.health (collectively, the "Site"), cloud platforms, and mobile applications and related technologies (the "Mobile App").

By using our Services, you are agreeing to New Dawn's Terms of Service (which incorporates this Privacy Policy by reference) and to the practices described in this Privacy Policy. Capitalized terms used herein but not defined shall have the meanings ascribed to them in our Terms of Service.

Before using the Service or submitting any Personal Information to us, please review this Privacy Policy carefully and contact us if you have any questions.

1. Sources of Personal Data

We collect Personal Information when you use our Services, create an account with us or provide Personal Information to us. "Personal Information" is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular individual, including, but not limited to, a first and last name, unique identifier, email address, a home, postal or other physical address, and phone number. The categories of Personal Information that we may collect about you are:

  • A. Information you provide to us. We collect information you give us when you create an account or use our interactive tools and services, such as searching for Providers or available appointments with Providers; when you provide information about yourself through booking an appointment; when you communicate with us through online form, chat, email, phone, or text; give us feedback; or when you otherwise choose to provide your information to us.
  • B. Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, such as through cookies and other tracking technologies, when you interact with our Services. This may include information about how you use and interact with our Services or otherwise interact with us, information about your device, and internet usage information.
  • C. From third parties. We may collect Personal Data from third parties, such as physicians, providers, other medical professionals, analytics providers, social networks, data brokers, and advertising providers that provide or sell lists of potential customers, social media companies, or other parties who interact with us.
  • D. From publicly available sources. We may collect Personal Data about you from publicly available sources, such as public profiles and websites. We may combine and use information and make inferences from information that we receive from the various sources described in this Privacy Policy, including third party sources. We may also use or disclose the combined information and inferences for the purposes identified below.

2. Personal Information We Collect

Category of Personal Data Examples of Personal Data Collected
Personal Identifiers First and last name, E-mail address, Phone number, Mailing address, Zip code
Commercial Information Payment card type, Last four digits of payment card, Billing contact, Billing email
Online Identifiers IP Address, Device ID, Domain server, Type of device/operating system/browser used to access the Services
Internet Activity Webpage interactions, Web analytics, Referring webpage/source through which you access the Services, Non-identifiable request IDs, Statistics associated with the interaction between your device or browser and the Services
Geolocation Data IP address-based location information
User Demographic Data Age, Date of birth, Zip code
Booking Appointment Data Appointment date/time, Provider information, Appointment procedure, Whether or not user is a new patient for a particular provider
Sensitive Personal Information Health information, such as: Health conditions, Healthcare Providers visited, Reasons for visit, Dates of visit, Medical history and health information you provide us.

Health Insurance information, such as: Insurance plan, Member ID, Group ID, Payer
Other Identifying Information Unique identifiers such as passwords, Personal Data in emails, letters, chat, text, or other communications you send to us, Social Network Data (for accounts you choose to link to the Services)

3. How We Use Personal Information

  • A. Providing, Customizing, and Improving the Services: Creating and managing your account or other user profiles; billing our healthcare provider clients; providing you with the products, services, and information you request; meeting or fulfilling the reason you provided the information to us; providing support and assistance for the Services; improving the Services, including testing, research, internal analytics, and product development; personalizing the Services, website content, and communications based on your preferences; fraud protection, security, and debugging.
  • B. Marketing the Services: Marketing and selling the Services; showing you advertisements, including interest-based or online behavioral advertising.
  • C. Creating de-identified data sets derived from Personal Data: This de-identified data often comes from the patient data we receive from Healthcare Providers or from your interaction with our Services. We maintain and use such information in deidentified form and do not attempt to reidentify the information, except as may be required or permitted by law.
  • D. Corresponding with You: Responding to correspondence that we receive from you, contacting you when necessary or requested, including to remind you of an upcoming appointment, and sending you information about New Dawn or the Services; sending emails and other communications that display content that we think will interest you and according to your preferences including notifying you about certain resources, Healthcare Providers or Services.
  • E. Legal Requirements: Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, New Dawn Labs Inc. or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; resolving disputes.

4. Sharing and Disclosure of Personal Information

We may share your Personal Information under specific circumstances, as outlined below:

  • Vendors and Service Providers: We share Personal Information with vendors and service providers who perform functions on our behalf, such as IT services, email communications, advertising, payment processing, insurance, security, customer support, and web analytics. These parties handle your data based on our instructions and in compliance with legal and contractual safeguards.
  • Within New Dawn: Personal Information may be shared with our affiliates as permitted by law and in line with this Privacy Policy. Where applicable, we ensure compliance with HIPAA or relevant health privacy legislation.
  • Business Transfers: In the event of a merger, acquisition, reorganization, or similar transaction, your Personal Information may be shared with involved parties and transferred to a successor as part of the process.
  • Legal Obligations: We may disclose Personal Information if required by law or when necessary to: comply with legal obligations or requests, including national security or law enforcement; protect our rights, property, or safety, or that of others; prevent fraud or address urgent security issues.
  • Social Sharing: If you use features that allow sharing your New Dawn experience on social media, we may share your selected information with those platforms per their respective privacy policies.

Data that is Not Personal Data

We may create aggregated and/or de-identified data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified, or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build, and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

We may also use screen recording tools in order to understand and analyze how individuals navigate and use our website. This technology will record mouse movements, clicks and similar actions, but we do not disclose any personal data with the screen recording tools and we do not link such information to your personal data.

In addition, we may use artificial intelligence ("AI") tools to enhance or operate certain functions of the site, such as chat, automated translation, and customer service features.

5. Data Security and Data Retention

We maintain reasonable security procedures and technical and organizational measures to protect your Personal Data against accidental or unlawful destruction, loss, disclosure or use. However, no data transmission over the Internet can be guaranteed to be fully secure. We recommend that you take reasonable precautions to protect the Personal Data you send and receive from us.

We keep Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting, medical record retention, or other purposes), whichever is longer.

6. Children

Our Services is not directed to children who are under the age of 18. We do not knowingly collect Personal Information from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Services please contact us and we will endeavor to delete that information from our databases.

7. International Users

By using our Service, you understand and acknowledge that your Personal Information will be transferred from your location to our operations in Taiwan and in the United States.

8. Your Preferences

You may email us to request corrections or changes to any Personal Data we maintain about you by using the contact information below in the "Contact Information" section.

You may opt out of receiving certain email communications from us by using the unsubscribe link in the footer of the email, updating your email preferences within your Services account settings (for registered users), or by contacting us to have your contact information removed from our promotional email list or registration database. Opting-out of certain email communications does not mean we will not contact you by email about your account or transactions between us.

9. External Links

Our Services may contain links to external sites or other online services that we do not control, including those embedded in third party advertisements or sponsor information. We are not responsible for the privacy practices or data collection policies of such third-party services. You should consult the privacy policies of those third-party services for details on their practices.

10. Cookies and Other Tracking Technologies

We use cookies to operate and administer our Service, gather usage data on our Service, and improve your experience on it. A "cookie" is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time.

  • Advertising Networks: Advertising networks may use cookies to collect Personal Information. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative's online resources at https://www.networkadvertising.org and follow the opt-out instructions there.
  • Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help us analyze how users use the Service and enhance your experience when you use the Service. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.
  • Bot Protection (reCAPTCHA): We use Google reCAPTCHA v3, a service provided by Google, Inc. ("Google"), to protect our forms from spam and abuse. reCAPTCHA collects information about your interactions with our website (including your IP address and browsing behavior) and shares it with Google to distinguish humans from automated bots. Your use of reCAPTCHA is subject to the Google Privacy Policy and Terms of Service.

Online Tracking and Do Not Track Signals

We and our third party service providers, including Meta, may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Services and use that information to send targeted advertisements. Some browsers have incorporated Do Not Track ("DNT") preferences. At this time, we do not honor Do Not Track signals.

11. Contact Information

If you have questions or complaints regarding our Privacy Policy or privacy practices, you can contact us at:

New Dawn Labs Inc.
Website: www.newdawn.health
Email: privacy@newdawn.health

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