Privacy Policy

Last updated: January 2025

This Privacy Policy describes the policies and procedures of ITO Health, PBC (“the Company,” “we,” “us,” or “our”) regarding the collection, use, and disclosure of your information when you use our marketing website at itohealth.org (the “Website”). By using the Website, you agree to the collection and use of information in accordance with this Privacy Policy.

Important Notice: No Protected Health Information

This Website is a marketing and informational site only. We do not collect, store, transmit, or process any Protected Health Information (PHI) as defined under HIPAA on this Website. Our clinical products (HealthBase, MediKey, etc.) operate on separate, HIPAA-compliant infrastructure with their own privacy practices and Business Associate Agreements.

Information We Collect

Information You Provide

When you use our contact form, you may voluntarily provide us with personally identifiable information including:

• Name
• Email address
• Organization name
• Job title or role
• Products of interest
• Message content

This information is stored securely in our database and used solely to respond to your inquiry and initiate a business conversation.

Information Collected Automatically

When you visit our Website, we may collect certain information automatically, including:

• Your device's Internet Protocol (IP) address, browser type, and browser version
• Pages visited, time and date of your visit, and time spent on pages
• Unique device identifiers and other diagnostic data

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to improve your experience on our Website and to understand how visitors interact with our content.

Analytics: Microsoft Clarity

We use Microsoft Clarity, a third-party analytics service provided by Microsoft Corporation. Clarity helps us understand how visitors interact with our Website by providing:

• Session recordings (anonymized replays of user interactions)
• Heatmaps showing where visitors click, scroll, and move their cursor
• Aggregated usage analytics and performance metrics

Clarity may use cookies and similar technologies to collect and process data. We have configured Clarity to mask sensitive form fields (such as contact form inputs) so that personally identifiable information is not captured in session recordings.

For more information about Microsoft Clarity, please visit Microsoft Clarity Terms of Service and Microsoft Privacy Statement.

How We Use Your Information

We may use the information we collect for the following purposes:

• To respond to your inquiries submitted through our contact form
• To understand how visitors use our Website and improve the user experience
• To monitor and analyze usage trends
• To ensure the security and integrity of our Website

Data Sharing

We do not sell your personal information. We may share your information only in the following limited circumstances:

• With service providers: We store contact form submissions securely in our database to respond to your inquiries.
• For legal compliance: We may disclose your information if required to do so by law or in response to valid requests by public authorities.
• Business transfers: In connection with any merger, acquisition, or sale of company assets, your information may be transferred as part of that transaction.

Data Retention

Contact form submissions are retained for as long as necessary to respond to your inquiry and maintain a record of our business communications. Usage data collected through Clarity is retained according to Microsoft's data retention policies.

Data Security

The security of your information is important to us. We use commercially reasonable measures to protect your data. However, no method of transmission over the Internet or method of electronic storage is 100% secure.

Your Rights

You have the right to:

• Request access to the personal information we hold about you
• Request correction or deletion of your personal information
• Decline analytics cookies by clicking “Decline” on our cookie consent banner
• Withdraw cookie consent at any time by clearing your browser cookies for itohealth.org

Children's Privacy

Our Website is not directed to individuals under the age of 13. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal data, please contact us and we will take steps to remove that information.

Links to Other Websites

Our Website may contain links to other sites that are not operated by us, including our product help center at help.itohealth.org and our product updates at updates.itohealth.org. We have no control over and assume no responsibility for the content or privacy policies of any third-party sites or services.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last updated” date at the top of this policy.

Governing Law

This Privacy Policy shall be governed by the laws of the State of Rhode Island, without regard to its conflict of law provisions.

Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data rights, please contact us:

• Email: hello@itohealth.org
• Address: ITO Health, PBC — 10 Davol Square, Unit 100, Providence, RI 02903

You may also visit our Contact page to send us a message directly.