Privacy

Privacy Policy

FINESTRA

PRIVACY POLICY

The website located at finestra.health, finestrahealth.com (collectively, the “Website”) and the Finestra mobile application (the “App,” and collectively with the App and the Website, the “Services”) are operated by Finestra, Inc. (“Finestra”, “we,” “us,” or “our). This Privacy Policy explains how we may collect and use personally identifiable information and non-identifying information about you when you access or use the Services.

Please read this page carefully. By accessing the Services or submitting your Personal Information (defined below) in order to receive the Services, you agree to the terms set forth in this Privacy Policy. IF YOU DO NOT ACCEPT THE TERMS OF THIS PRIVACY POLICY, DO NOT ACCESS OR USE THE SERVICES.

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the modified Privacy Policy and its effective date on this page. Accordingly, you should visit this page periodically to review and understand any such changes. By continuing to access or use the Services after a modification, you agree to be bound by the modified Privacy Policy.

1. INFORMATION COLLECTED BY FINESTRA

a. Collection of Personal Information

“Personal Information” means all personally-identifiable information (such as e.g., your name, physical address, e-mail address, home and mobile telephone numbers, or birth date) that you submit in connection with the Services. Finestra does not collect Personal Information unless you voluntarily submit it in connection with your use of the Services, send inquiries to Finestra, or participate in certain activities available via the Services. We collect Personal Information when you choose to use certain features of the Services, including when you: (i) create an account on the Website or the App; (ii) engage in certain activities available via the Services, such as uploading content including health insurance information; or (iii) consent to receive commercial or promotional email, direct mail, or SMS/text messages about upcoming promotions or events.

We may collect personal information about consumers that is considered “protected health information” (“PHI”) that we receive directly from you. PHI is governed by the privacy, security, and breach notification provisions of federal laws known as HIPAA (the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191) and HITECH (the Health Information Technology for Economic and Clinical Health Act, Public Law 111-5), and their implementing regulations (Parts 160 and 164 of the Code of Federal Regulations). State law may provide additional requirements for PHI. This Privacy Policy does not cover PHI we collect about you because we are not a healthcare provider, or otherwise a covered entity or business associate subject to HIPAA. If you want to know how your healthcare providers and their business associates safeguard, use, and disclose PHI about you, ask your healthcare provider for its “Notice of Privacy Practices.”

b. Information Gathered Automatically

Finestra automatically collects certain non-identifying information about you (such as your movement about the Website or App, the pages you visit most frequently, the type of browser or computer operating system you use, or the domain name of the website from which you link).

In addition, Finestra may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices’ unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browsers you use, and the information about the way you use the Services.

Finestra uses “cookies” to customize and improve your use of the Services. Cookies are small pieces of information or data stored on your computer or mobile device that are used to determine your preferences and track certain behavior or activities when you use the Services. If you object to this practice, you may erase or block cookies. We recommend, however, that you allow cookies to be stored on your computer or mobile device as they may be needed to properly use the Services.

c. Information on Location Data

When you use our Services, we may use GPS technology (or other similar technology) to determine your current location in order to determine clinics, hospitals, and other healthcare providers near you and provide you the relevant information and advertisements. Based on your user setting, we may share your current location with other users or partners to customize your Services experience and view more relevant information.

If you do not want us to use your location for the purposes set forth above, you should turn off the location services for the mobile application located in your account settings or in your mobile phone settings and/or within the mobile application. Please note, if you turn off the location services, some functions of the Services will be unavailable.

2. USE OR DISCLOSURE OF PERSONAL INFORMATION

Finestra may use your Personal Information to contact you regarding the Services. We may also use your Personal Information to provide services requested by you and for internal research and marketing purposes. We may share your Personal Information and non-identifying information that we collect from you with our parent, subsidiaries, divisions, or affiliates.

Finestra will not use, disclose, or sell your Personal information to any third parties for any purposes other than those necessary to deliver the Services. For example, it is necessary for us to provide information on location data to healthcare providers in order to determine clinics, hospitals, and other healthcare providers near you and provide you the relevant information and advertisements. Otherwise, we will not sell or transfer to unaffiliated third parties any Personal Information that you submit or any non-identifying information collected without your consent. The Personal Information and non-identifying information we collect from you may be used as follows:

i. to present our Services and its contents to you, including to personalize your experience and better respond to your individual needs;

ii. to improve the Services;

iii. to improve customer service;

iv. to administer contests, promotions, surveys or other features for the Services;

v. to send periodic mailings concerning information and updates pertaining to Finestra;

vi. to send special or promotional offers or discounts related to Finestra or its affiliates and information related to products you have viewed via the Services;

vii. to provide you with information, products, or services that you request from us;

viii. to help maintain the safety, security, and integrity of our Services, databases and other technology assets and business; or

ix. as an asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control.

Notwithstanding the foregoing or any other statements or representations here or elsewhere, Finestra reserves the right to disclose any Personal Information in our possession if Finestra believes that such disclosure is necessary: (i) to conform to legal requirements or to respond to a subpoena, search warrant, or other legal process received by Finestra, whether or not a response is required by applicable law; (ii) to enforce or protect Finestra’s rights; or (iii) to protect the safety of users of Finestra’s Services and members of the general public.

WE ARE NOT RESPONSIBLE FOR THE PERSONAL INFORMATION AND OTHER NON-IDENTIFYING INFORMATION YOU CHOOSE TO SUBMIT IN ANY PUBLICLY ACCESSIBLE AREA OF THE SERVICES.

3. SECURITY

Finestra has reasonable security measures in place to protect Personal Information you submit in order to receive the Services. However, the transmission of information via the internet is not, and cannot be made, completely secure. We cannot and do not guarantee, ensure, or warrant that personal information will be completely secure from misappropriation by hackers or from other bad actors or criminals, or from the failure of computer hardware, software, or telecommunications networks. Finestra assumes no responsibility for the security of any Personal Information you submit. We will notify you, as required by law, if we discover a security breach involving your Personal Information (as defined by the applicable state and federal laws) processed by us.

4. LINKS

We may permit certain third parties to link to our Services, and the Services may contain links to third-party sites. Finestra is not responsible for the privacy policies or practices of such third parties, including on such third parties’ websites. When linking to a third party website, you should read the privacy policy stated on that website. This Privacy Policy only governs Personal Information, non-identifying information and content collected in connection with the Services.

5. ADDITIONAL PROTECTIONS FOR CHILDREN

The Services are not designed for or targeted to children under the age of 13, and Finestra will never knowingly solicit or collect the Personal Information of a child under the age of 13. If we discover that Personal Information of a child under the age of 13 has been submitted without verifiable parental consent, we will immediately delete such Personal Information.

6. YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information, including the right to request businesses to tell you how your personal information has been shared with third parties, if at all, for the third parties’ direct marketing purposes. To make such a request, please contact us at the contact information listed below.

7. CONTACT INFORMATION

If you have any questions about this Privacy Policy or your dealings with Finestra, please feel free to contact us at:

Finestra, Inc. 245 8th Avenue #1071 New York, NY 10011. Email: contact@finestrahealth.com

Effective date: 09/24/2021