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TRUENORTH HEALTHCARE

PRIVACY POLICY

This Privacy Policy was last updated on January 31, 2013.

Our Policy:

Welcome to the website (the “Site”) of myProxy, Inc., doing business as TrueNorth Healthcare (“TrueNorth,” “Company,” “we,” “us,” “our”). This Site is operated by TrueNorth and has been created to provide an online platform for advance medical planning (the “Services”) for our Site visitors (“user,” “you,” or “your”). TrueNorth takes your privacy seriously. We strive to keep your personal and medical treatment information secure. This Privacy Policy sets forth TrueNorth’s policy with respect to data collection, processing and usage practices of TrueNorth. By using the Site or Services, you consent to the data practices described in this Privacy Policy.

Information We Collect:

When you interact with us through the Services, we may collect personally-identifiable data (“Personal Data”) and other information from you, as further described below:

Personal Data That You Provide Through the Services: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain Services. Such Personal Data may include, but is not limited to, your name, address, telephone number, and e-mail address. Wherever TrueNorth collects Personal Data, we make an effort to provide a link to this Privacy Policy.

We may also collect Personal Data of third parties when you voluntarily provide us with such information. For example, we may collect Personal Data when you designate a person to make healthcare decisions for you if at any time you are not able to (the “healthcare advocate”). We may also collect Personal Data when you identify personal contacts for any advance medical plan (the “TruePlan”) you create through the Services.

We may also collect third-party Personal Data for the TrueNetwork feature. This allows a user to designate a healthcare advocate and add personal contacts so that those contacts can be contacted in regards to any choices made related to your TruePlan. We may send each of these identified individuals a onetime email notifying of them of your decision that they be contacted.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of TrueNorth and the authorized third parties referred to herein located in the United States and abroad.

Other Information:

Non-Identifiable Data: When you interact with TrueNorth through the Services, we receive and store certain personally non-identifiable information about you and/or your activity on the Services, such as the pages of the Site you have visited, your IP address and related information. TrueNorth may store such information itself or such information may be included in databases owned and maintained by TrueNorth affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers.

Also, in operating the Services, we may use "cookies." A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. We may also use cookies to help track the level of interest in different features of our Site and to compile data that can help us improve our Services. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Services, TrueNorth often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and TrueNorth may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. TrueNorth may also disclose aggregated user statistics for purposes of research and scientific studies or in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.

Our Use of Your Personal Data and Other Information:

TrueNorth uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. TrueNorth may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services. TrueNorth may use this information to contact you in the future to send you newsletters or tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to "opt-out" of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

If TrueNorth intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, we intend to inform you of such anticipated use prior to such use.

Our Disclosure of Your Personal Data and Other Information:

TrueNorth may share your Personal Data with non-affiliated third parties when we believe sharing is permitted by you or authorized by this Privacy Policy. In addition, we may share your Personal Information with partners such as healthcare providers, insurers or businesses which aide us in delivering services to you or for their health care operation purposes. In addition, the Services may allow you to designate individuals who are authorized to have access to your TruePlan or other Personal Data about you. At your direction, these individuals may include relatives, friends, or other third parties. Our Services may also allow you to designate a healthcare advocate. By designating such a healthcare advocate, TrueNorth may allow your designated healthcare advocate to authorize other third parties to have access to your TruePlan or other Personal Data about you.

There are certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Related Companies: We may also share your Personal Data with our affiliates and subsidiaries for purposes consistent with this Privacy Policy.

Agents, Consultants and Related Third Parties: TrueNorth, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, customer service, data storage, and special promotions. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function, and we take reasonable steps to ensure that these third parties protect your Personal Data in accordance with our confidentiality standards.

Legal Requirements: TrueNorth may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of TrueNorth, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

Your Choices:

You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.

Publicly-Available Information:

TrueNorth may collect testimonials from users regarding the Services. With your consent, we may post your testimonial along with your name. If you want your testimonial removed, please contact us at info@truenorthhealthcare.com.

TrueNorth may also offer publicly-accessible blogs or community forums. You should be aware that any information you provide in these areas is publicly-accessible and may be read, collected, copied, and used by others who access them. If you decide to post Personal Data to these publicly-accessible blogs or community forums, TrueNorth cannot limit access to such posted Personal Data. To request removal of your Personal Data from our blog or community forum, please contact us at info@truenorthhealthcare.com. In some cases, we may not be able to remove your Personal Data, in which case we will endeavor to let you know if we are unable to do so and why.

Exclusions:

This Privacy Policy does not apply to any Personal Data collected by TrueNorth other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to TrueNorth through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and TrueNorth shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Children and Minors:

TrueNorth does not knowingly collect Personal Data from minors under the age of 18. If you are under the age of 18, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a minor under the age of 18 has provided Personal Data to TrueNorth through the Services, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites:

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by TrueNorth (the “Third-Party Sites”). The policies and procedures we described here do not apply to the Third-Party Sites. The links from the Services do not imply that TrueNorth endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Integrating Social Networking Services:

One of the special features of the Service is that it allows you to enable or log in to the Services via various social networking services like Facebook or Twitter (“Social Networking Service(s)”). By directly integrating these services, we make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to log into or grant us permission via the relevant Social Networking Service. When you add a Social Networking Services account to the Service or log into the Service using your Social Networking Services account, we will collect relevant information necessary to enable the Service to access that Social Networking Service and your data contained within that Social Networking Service. As part of such integration, the Social Networking Service will provide us with access to certain information that you have provided to the Social Networking Service, and we will use, store and disclose such information in accordance with this Privacy Policy. However, please remember that the manner in which Social Networking Services use, store and disclose your information is governed by the policies of such third parties, and Company shall have no liability or responsibility for the privacy practices or other actions of any Social Networking Services that may be enabled within the Service.

You may also have the option of posting your Services activities to Social Networking Services when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity.

The Service also includes social media features (“Features”), such as the Facebook Like button and widgets, such as the "Share This" button or interactive mini-programs that run on this Site (“Widgets”). These Features and Widgets may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the Feature or Widget to function properly. Social media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Security:

TrueNorth will strive to maintain your privacy, confidentiality, and security in accordance with this Privacy Policy. TrueNorth takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to TrueNorth via the Internet.

TrueNorth’s California Do Not Track Notice:

This Privacy Policy sets forth the manner in which TrueNorth collects, uses, shares and discloses your Personal Information through the Service. We support Do Not Track and follow whatever DNT preferences you have set in your browser. TrueNorth currently does not authorize third parties to collect users’ Personal Information through the Service.

Other Terms and Conditions:

Your access to and use of the Services is subject to the TrueNorth Terms of Service.

Changes to TrueNorth’s Privacy Policy:

The Services and our business may change from time to time. As a result, at times it may be necessary for TrueNorth to make changes to this Privacy Policy. TrueNorth reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Accessing, Correcting, or Deleting Your Personal Data:

You may change, update, or delete your Personal Data at any time by returning to the My Dashboard section of TrueNorth. You should be aware that it is not always technically possible to remove, change, or delete all the information, including Personal Data, you previously provide to TrueNorth. We back up our systems to protect information from inadvertent loss, and that means a copy of your Personal Data may exist in a non-erasable form that may be difficult or impossible for us to locate. Nevertheless, upon receiving your request we will try to remove or delete all Personal Data and/or medical treatment choices information stored in the active databases that we use for research and daily business activities. We will not intentionally disclose any Personal Data stored in a non-erasable format after receiving your request for removal, except as required by law or provided in this Privacy Policy. If you choose to de-register from TrueNorth and request deletion by TrueNorth of all your Personal Data, TrueNorth may be required to inform third parties of your decision to de-register, including your insurance providers or healthcare providers.

Contacting TrueNorth:

Please feel free to contact us at info@truenorthhealthcare.com if you have any questions about TrueNorth’s Privacy Policy or the information practices of the Services.