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Privacy Policy

INTEMPO HEALTH PRIVACY POLICY


Intempo Health Data Application


Last Updated: April 25, 2025


1. INTRODUCTION
Intempo Health, Inc. (“Intempo”, "we", "us", or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and protect your information when you use our Intempo Health mobile application, website and related services (collectively, the "Service" or “Services”).


Our Services are designed to help you manage and utilize your health information and may, with
your authorization and initiation, collect both Protected Health Information (PHI) and non-PHI
data. As a current or prospective covered entity under the Health Insurance Portability and
Accountability Act of 1996 (HIPAA), we comply with all applicable requirements of HIPAA and its
implementing regulations.


2. INFORMATION WE COLLECT


2.1 Protected Health Information (PHI)


We may collect the following types of PHI, including but not limited to:

  • Medical records and health history

  • Treatment information

  • Diagnostic information and test results

  • Real world data, like that information you track on external devices and health

  • applications like smart watches, rings, health applications and others

  • Medication information

  • Health insurance information

  • Billing and payment information

  • Provider names and contact information

  • Other health-related data that could be used to identify you


2.2 Non-PHI Personal Information


We may also collect:

  • Account information (name, email address, password)

  • Demographic information (including but not limited to age, gender, location)

  • Device information (device type, operating system, IP address)

  • Usage data (how you interact with our app, features used)

  • Communications (for example, when you contact our support team)

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2.3 Collection Methods


We collect information directly from you when you do things like, but not limited to:

  • Create an account and set up your profile

  • Input health and other data manually into the app

  • Connect external devices or health applications

  • Upload documents, images, and/or audio and video files

  • Communicate with healthcare and other providers through the app

  • Contact our customer support


3. HOW WE USE YOUR INFORMATION


3.1 Use of PHI


We will only use your PHI, with your authorization, for:

  • Providing healthcare-related services and providing tools that may facilitate treatment

  • Payment operations and insurance verification

  • Healthcare-related operations (quality assessment, customer service, etc.)

  • Other purposes for which you have provided specific consent

  • Meeting legal and regulatory requirements


3.2 Use of Non-PHI Data


We may use non-PHI data for things like, but not limited to:

  • Creating and maintaining your account

  • Improving and personalizing our Service

  • Analyzing usage patterns to enhance features

  • Communicating with you about updates or changes

  • Technical support and troubleshooting

  • Marketing our services (in de-identified or aggregated form, or if not in such form, then

  • only with your consent)


4. LEGAL BASIS FOR PROCESSING


Our processing of your personal information is based on:

  • Your explicit consent

  • Performance of our contract with you

  • Compliance with legal obligations

  • Legitimate business interests (when not overridden by your rights)

  • Protection of vital interests in medical and other emergencies


5. DATA SHARING AND DISCLOSURE


5.1 PHI Disclosure


We will only disclose your PHI:

  • To healthcare providers involved in your care, with your authorization

  • For treatment, payment, or healthcare operations, with your authorization

  • To business associates with appropriate safeguards

  • When required by law or for public health activities

  • In response to a court order or subpoena

  • To prevent a serious threat to health or safety

  • For other purposes allowed by HIPAA

  • With your explicit authorization


5.2 Non-PHI Disclosure


We may share non-PHI with:

  • Service providers who help operate our app

  • Analytics partners (in de-identified or aggregated form)

  • In connection with a business transfer or reorganization

  • When required by law, to protect your rights (when possible), or to protect our rights


6. DATA SECURITY MEASURES


We implement appropriate administrative, physical, and technical safeguards to protect your
information, including:

  • Encryption of data in transit and at rest

  • Access controls and authentication requirements

  • Regular security assessments and audits

  • Staff training on privacy and security

  • Secure data storage and backup procedures

  • Incident response planning

  • Business continuity protocols


7. DATA RETENTION


We retain your information for as long as:

  • Your account remains active

  • Needed to provide our services

  • Required to comply with legal obligations

  • Necessary for legitimate business purposes

  • Medical records are typically retained for periods required by state law (commonly 6-10 years or

  • longer depending on your jurisdiction).


8. YOUR RIGHTS

​

  • Under HIPAA and applicable privacy laws, you have the right to:

  • Access your PHI and obtain copies

  • Request amendments to inaccurate information

  • Receive an accounting of certain disclosures

  • Request restrictions on certain uses and disclosures

  • Request confidential communications

  • Receive notification of a breach

  • File a complaint if you believe your privacy rights have been violated

  • Opt-out of certain data uses where applicable


9. CHILDREN'S PRIVACY


Our Service is not intended for children under 16 years of age. We do not knowingly collect
personal information from children under 16. If we discover that a child under 16 has provided
us with personal information, we will promptly delete such information.


10. CHANGES TO THIS PRIVACY POLICY


We may update this Privacy Policy periodically to reflect changes in our practices or for other
operational, legal, or regulatory reasons. We will notify you of any material changes by:

  • Posting the new Privacy Policy on our Services

  • Updating the "Last Updated" date

  • Sending an email notification if we have your contact information


11. CONTACT US


If you have questions about this Privacy Policy or our privacy practices, please contact:
ATTN: Privacy Officer
Intempo Health, Inc.
privacy@intempohealth.com


12. HIPAA NOTICES AND FORMS


Our Notice of Privacy Practices, providing more detailed information about how we use and
disclose your PHI, is available on our website, and app, when possible.
Authorization forms for the release of information are available upon request.


13. STATE-SPECIFIC PROVISIONS


Depending on your state of residence, you may have additional rights regarding your personal
information. Please contact us for state-specific information.

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By using our Service, you acknowledge that you have read and understand this Privacy Policy
and agree to its terms.

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