Online Privacy Policy

Introduction

Hola Doctor, Inc. and its controlled affiliates (collectively, “HD”) developed this Online Privacy Policy to provide you with information about our privacy practices and to help you understand your privacy choices when you use our websites and portals.
Our Commitment to Privacy
HD believes in the value of privacy; therefore, our privacy commitments are fundamental to the way we run our business. We intend to safeguard all personal information that is collected from you when you visit and use our websites and portals.
This Online Privacy Policy explains how we protect personal data collected on our websites and portals. It includes the following topics:

1. What is covered by this Online Privacy Policy?
2. What information we collect from you?
3. Our use of “Cookies”
4. Our use of Personal Information
5. Sharing of Personal Information
6. International Transfers of Personal Information
7. How long do we keep Personal Information?
8. How do we protect Personal Information?
9. Links to Third Party Websites
10. How do we manage the information of a child?
11. Your Rights
12. Contacting us about privacy questions or concerns
13. Online Privacy Policy changes

1. What is the scope of this Online Privacy Policy?
This Online Privacy Policy describes the privacy practices applicable to our online and offline collection, use, sale, and disclosure of personal information.
To review online privacy policy applicable to California residents please click here.

2. What information we collect from you?
These are examples of the personal information we may collect about you:
1. Information that identifies you, for example:
• First and last name
• Address
• Phone number
• Email
• IP address
• Device Information
• Information collected from cookies or other tracking technologies
2. Records and financial information, for example:
• Social Security Number
• Government-issued identification
• Bank account and routing numbers
• Credit and debit card information
• Financial information
3. Personal characteristics, for example:
• Age
• National origin
• Disability
• Citizenship
• Military status
4. Commercial information, for example:
• Online shopping cart information
• Purchase history
5. Internet or network activity, for example:
• Interactions with our services or sites
• Shopping history
6. Geolocation data, for example:
• Global Positioning System (GPS) information when you give us permission through your device settings
• IP-based geolocation
7. Audio, electronic, visual, biometric, or similar information, for example:
• Call recordings when you talk to customer service
• Voice identification, when you consent to this biometric method of authentication
• Photo IDs and profile pictures you provide
8. Professional or employment information, for example:
• Business information, contact emails and phone numbers
• Tax IDs
9. Information we infer based on your personal data, for example:
• Fraud and risk assessments
• Personalization preferences

3. Where does the information we collect about you come from?
Data collected directly from website visitors. In most instances, you can visit our websites without providing any personal data. However, on some pages, you may give us your personal data (i.e. information that identifies or reasonably can be used to identify you) by filling out forms. This includes personal data you provide when you:
• request information on our products or services
• create an account on our website
• subscribe to our blog or newsletter
• request marketing information
• enter a competition, promotion or survey
• give us feedback or contact us
• apply for employment
You are not required to provide any of the above-mentioned information. However, if you choose not to, we may not be able to provide you the requested service or complete your transaction.

Data collected from portal visits. In order to access the portals you will need to provide sufficient data to create an account. Additionally, and subject to your relationship with HD, you may make requests that involve collecting additional personally identifiable information, personal health information and personal financial information.
Data collected by automated means. We collect certain data about all visitors to our websites and portals, including what pages they view, the number of bytes transferred, the links they click, and other actions taken within our websites and portals. We may also use this information to improve our security measures. We also collect certain standard information that your browser sends to every website you visit, such as your Internet Protocol (IP) address, your browser type and capabilities and language, your operating system, the date and time you access the site, and the website from which you linked to our site.
Data collected from third parties. We may collect personal information about you from various sources, including:
Public records
Financial institutions, such as banks
Credit bureaus
Service providers
Third-party data providers
Government agencies and contractors

If you have an account with us, we will associate information from all these sources with your account and we will use it for the purposes set out in this policy.

4. Our use of “Cookies”
Cookies are small files that websites and portals save to your hard disk or to your browser’s memory. Our websites may use them to track the number of times you have visited the websites, to track the number of visitors to the websites, to determine and analyze visitors’ use of our websites, to store data that you provide (such as your preferences), and to store technical information related to your interactions with our websites. We may also use session cookies, which are deleted when you close your browser, to store your user ID, to facilitate your movement around our websites.
Our websites may also contain electronic images known as Web beacons—sometimes called single-pixel gifs—that allow us to count the number of users who have visited those pages.
Adjusting Browser Settings to Manage Cookies or Send “Do Not Track” Signals:
Most Internet browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed on your computer. If you choose not to accept cookies, you may not be able to experience all of the features of our websites. Internet browsers also enable you to delete existing cookies, although this means that your existing settings (including stored user IDs and other preferences) will be lost. Some web browsers may also give you the ability to enable a “do not track” setting. This setting sends a signal to the websites you encounter while web browsing. This “do not track” signal is different from disabling certain forms of tracking by declining cookies in your browser settings, as browsers with the “do not track” setting enabled may still accept cookies. HD does not respond to web browser “do not track” signals at this time. If we do so in the future, we will describe how we do so in this Privacy Policy.
Social Media Third Party Cookies
During your visit to our websites, you may notice embedded content from other social media websites such as YouTube, Twitter or Facebook, and you may be presented with cookies from these websites. HD has no control or are responsibility for those cookies. You should check the third party’s cookie policy for more information.

5. Our Use of Personal Information
We will use your personal data only for the purposes set forth below.
Services and transactions. We use personal data to deliver services or execute transactions you request, such as providing information about HD products and services, answering customer service requests, facilitating use of our website and portals, and so forth. In order to offer you a more consistent experience in interacting with HD, information collected by our websites and portals may be combined with information we collect by other means, i.e. phone, e-mail or paper.
Website and portal improvement. We may use data about you to improve our websites and portals (including our security measures) and related products or services, or to make our websites and portals easier to use by eliminating the need for you to repeatedly enter the same information, or by customizing our websites to your particular preference or interests.
Market products and sales activities. We use personal data to inform you of available products or services. HD may also use personal information to advertise its products and services or related products and services, and also to have our affiliated and non-affiliated entities market products and services to you. This includes sending you promotional communications, target advertising, and presenting you relevant offers.
When collecting information that might be used to contact you about our products and services, we give you the opportunity to opt-out from receiving such communications. Moreover, each email communication we send includes an unsubscribe link allowing you to stop delivery of that type of communication. If you elect to unsubscribe, we will remove you from the relevant list within 10 business days.
Employment Applications. In connection with a job application or inquiry, you may provide us with data about yourself, including your educational background, résumé or curriculum vitae, and other information, including your ethnicity where required or permitted by law. We may use this information throughout HD for the purpose of employment consideration. We will keep the information for future consideration unless you direct us not to do so.

6. Sharing of Personal Information
HD will share your personal information collected from our websites and portals with third parties only in ways that are described in this Online Privacy Policy.
Disclosure to service providers. HD contracts with other companies to provide services on our behalf, such as hosting websites, sending out information, processing transactions, and analyzing our websites. We provide these companies with only those elements of personal data they need to deliver those services. These companies and their employees are prohibited from using the personal data for any other purposes.
Disclosure for other reasons. We may disclose personal data if required to do so by law or in the good-faith belief that such action is necessary to comply with legal requirements or respond to court orders, to protect and defend our rights or property, or in urgent circumstances to protect the personal safety of any individual.
Third-Party Processing. We may share your personal data with HD distributors or resellers for further follow-up related to your interests, specific partners that offer complementary products and services or with third parties to facilitate interest-based advertising.
When we share Sensitive Information or other personal data with our business partners and other third parties for business or commercial purposes, we require them to exercise reasonable care to protect such information and restrict the use of such information to the purposes for which it was provided to them.

7. International Transfers of Personal Information
HD may share your personal data within the affiliates of Pan-American Life Insurance Group (it’s parent company) for a variety of purposes, for example to provide you with the latest information about our products and services and offer you our latest promotions.
The countries, including the U.S. (and the other countries around the world where our individual affiliates, suppliers, or business partners maintain offices), to which we may transfer such information may have different data protection laws than the countries from which the information was initially collected or from which individual website or portal visitors access the website or respective portal.
By choosing to use our websites and portals and to submit personal data to us through them, you consent to the transfer of such information outside of your country. To the extent required by applicable law, when we transfer your personal information to recipients in other countries, we will take measures to protect that information.

8. How long do we keep personal information?
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period if we have a legal obligation to do so (e.g. in the event of a complaint or if we reasonably believe there is a prospect of litigation, or regulatory investigation). .
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

9. How do we protect personal information?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Links to Third Party Websites
Our websites may contain links to other websites on the Internet that are owned and operated by third parties. These websites operate independently from ours, and we do not control and are not responsible for the content, security or privacy practices employed by other websites. You should review the privacy statements of those websites to determine how they protect and use personal data.

11. How do we manage the information of a child?
Our websites are not intended for children under 13 years of age. We do not knowingly gather information from anyone under age 13. If we find out that we have collected information from a child under age 13, we will delete that information immediately.

12. Your Rights
To the extent provided by the law of your jurisdiction, you may have rights such as to (1) access certain personal information we maintain about you; (2) request that we update, correct, amend, erase or restrict your personal information; or (3) exercise your right to data portability; or log a complaint with the appropriate regulator. Additionally, and where provided by the applicable law, you may withdraw consent you previously provided to us or object at any time to the processing of your personal information on legitimate grounds relating to your particular situation, and we will examine your request and, when applicable, update your preferences going forward as appropriate. To exercise these rights, please contact our Privacy Office at privacy@holadoctor.com.
We try to respond to all legitimate requests within thirty (30) days. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13. Contacting us about privacy questions or concerns
If you have any questions about this privacy policy, or our handling of personal data, please contact us by email to privacy@holadoctor.com or HD’s physical address at 800 Old Roswell Lakes Parkway, Suite 150, Roswell, GA 30076.

14. Online Privacy Policy Changes
HD may occasionally update this Online Privacy Policy. When we do, we will revise the “last update” date at the bottom of the Online Privacy Policy. You should revisit this page periodically to become aware of the most recent privacy terms; your use of the websites and portals after such changes have been posted constitutes your agreement to such changes.

This Privacy Policy was last updated as of April 12, 2022.