Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.

Key Terms

It would be helpful to start by explaining some key terms used in this policy:

Term	Explanation
We, us, our	CONNEQT® , LLC, a FL limited liability company having a principal office of 111 E. Broward Blvd. Ste. 1700 Ft. Lauderdale, FL 33301
You, your	The user accessing conneqt.care
Our Representative and Data Protection Officer	Wesley Roberts, wroberts@conneqt.care
Personal information	Any information relating to an identified or identifiable individual

Personal Information We Collect About You

We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers) Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)	First and last name Email address Telephone number IP address Name of your business Physical address Social security number Protected health information
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, such as a credit card number, debit card number, or any other financial information.	Credit card or debit card information for payment processing Billing address
Characteristics of protected classifications under California or federal law.	Any user-input information
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)	Browser and site cookies Online identifiers Data trackers Pages accessed Bandwidth usage Operating system Browser Responses to forms
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	Site Usage

This personal information is required to provide CONNEQT® products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing the CONNEQT® products and services to you.

How Your Personal Information is Collected

We collect most of this personal information directly from you—either in person, by telephone, text, or email, and/or via our website and mobile apps. However, we may also collect information:

From a third party with your consent (e.g., your mobile carrier);
From cookies on our website; or
Via our IT systems, including automated monitoring of our site and other technical systems such as a communications systems, email, and instant messaging systems; or
Provided to Connect directly by you.

How and Why We Use Your Personal Information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:

To comply with our legal and regulatory obligations;
For the performance of our contract with you or to take steps at your request before entering into a contract;
For our legitimate interests or those of a third party; or
Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for:	Our reasons
To provide CONNEQT® services to you	For the performance of our contract with you or to take steps at your request before entering into a contract
To provide access to you to your user account	To administer your user account and to manage your user account
To prevent and detect fraud against you or CONNEQT®	For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analyses to help us manage our business, e.g., in relation to our financial performance, customer base, product range, or other efficiency measures	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing legal or health care appointment scheduling, matching, and payment processing
Ensuring HIPAA compliance	To comply with our legal and regulatory obligations when providing you private access to your own protected health information and when facilitating transmission of your protected health information between your legal service provider and your health care provider
Ensuring safe working practices, staff administration, and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to: Existing and former customers; Third parties who have previously expressed an interest in our services; Third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers

Promotional Communications

We may use your personal information to send you updates (by email, text message, telephone, or post) about our products such as e-books, new third-party integrations, legal referral or database services, or health care referral or database services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell it OR share it with other organizations outside the CONNEQT® group and affiliates for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by doing any of the following:

Contacting us at customersupport@conneqt.care ;
Using the “unsubscribe” link in emails or “STOP” number in texts; or
Updating your marketing preferences on our Site at Conneqt.com.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who We Share Your Personal Information With.

We routinely share personal information with:

Our affiliates, including companies within the CONNEQT® group;
Service providers we use to help deliver our products and/or services to you, such as payment service providers, advertising network providers,;
Other third parties we use to help us run our business, such as marketing agencies or website hosts;
Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
Third-party advertising networks to display advertising on our Site or to manage our advertising on other sites.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Personal Information We Disclosed for a Business Purpose

In the preceding 12 months, we have disclosed to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers);
Characteristics of protected classifications under California or federal law;
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
Regional geolocation data; and
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Where Your Personal Information is Held

Information may be held at our offices in the United States and in those of our affiliates, third party agencies, service providers, representatives, and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties may be based outside the European Economic Area. For more information, including how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or while we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly; or
To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

Transferring Your Personal Information Out of the EEA.

To deliver services to EU users, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

With our offices outside the EEA;
With your and our service providers located outside the EEA;
If you are based outside the EEA; or
Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law.

If you would like further information, please contact our Data Protection Officer (see “How To Contact Us” below).

Your Rights Under the GDPR.

Right	Explanation
Right to Access	The right to be provided with a copy of your personal information (the right of access)
Right to Rectification	The right to require us to correct any mistakes in your personal information
Right to be Forgotten	The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data Portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object	The right to object: at any time to your personal information being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

Your Rights Under the CCPA.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know:

The categories of personal information we have collected about you;
The categories of sources from which the personal information is collected;
Our business or commercial purpose for collecting or selling personal information;
The categories of third parties with whom we share personal information, if any; and
The specific pieces of personal information we have collected about you.
Please note that we are not required to:
Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;